Justia Civil Procedure Opinion Summaries

The Supreme Court affirmed the judgment of the superior court affirming a decision of the Rhode Island Department of Labor and Training (DLT) that denied Petitioners' wage and hour claims against Delta Airline, Inc., holding that the superior court did not err in affirming the DLT's finding that R.I. Gen. Laws 25-3-3 was preempted by federal law.Petitioners were customer service agents for Delta at its facility at the T.F. Green Airport in Warwick, Rhode Island. Petitioners filed separate individual "nonpayment of wages" complaints with DLT, alleging that Delta violated the provisions of section 25-3-3 by failing to pay Petitioners time-and-a-half for hours worked on Sundays and holidays. The hearing officer determined that section 25-3-3 was preempted by section 49 U.S.C. 41713(b)(1) of the Airline Deregulation Act (ADA). The superior court affirmed. The Supreme Court affirmed, holding that Petitioners' claims were preempted by the ADA. View "Brindle v. Rhode Island Department of Labor & Training" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Defendants on the grounds that the case was moot, holding that there was no justiciable controversy before the Court and that Plaintiffs failed to meet the burden of demonstrating that the issues raised in their complaint were of extreme public importance and were capable of repetition yet will evade review.After the National Education Association Rhode Island and the Middletown Teachers' Association/NEA (collectively, the Union) and the Middletown School Committee (school committee) reached a tentative successor agreement to a collective bargaining agreement (CBA) that was due to expire the Town of Middletown refused to ratify the agreement. The Union filed suit challenging the denial. Thereafter, the parties agreed to a new three-year CBA, and the Town voted to ratify the agreement. The trial justice granted summary judgment for Defendants, the Town, the school committee, and the Middletown School Department. The Supreme Court affirmed, holding that the trial justice did not err in granting summary judgment on the basis of mootness and that no exceptions to the mootness doctrine existed. View "National Education Ass'n Rhode Island v. Town of Middletown" on Justia Law

The Supreme Court vacated the judgments of the superior court granting summary judgment in favor of the defendant and the third-party defendant (collectively, Defendants) on Plaintiff's complaint alleging negligence for her injuries and the third-party complaint seeking to defend, indemnify, and hold the third-party defendant harmless for claims arising out of the third-party defendant's duty under Defendants' snow services agreement, holding that genuine issues of material fact existed precluding summary judgment.Specifically at issue before the trial justice was whether there were genuine issues of material fact as to the dangerous condition that caused Plaintiff's fall that would preclude summary judgment. The trial justice weighed the evidence before her at least twice during the summary judgment hearing. The Supreme Court vacated the superior court's judgments, holding that the trial justice improperly weighed the evidence before her at the summary judgment hearing. View "Voccola v. Stop & Shop Supermarket Co." on Justia Law

In these actions challenging the assessment of alleged illegal real estate taxes on several properties and property owners, the Supreme Court affirmed the judgment of the superior court in favor of Defendants in the declaratory judgment action and denied and dismissed the appeal in the tax appeal action, holding that the Plaintiff did not have standing in either action.Defendants were various officials of the Town of Barrington, Rhode Island; Sweetbriar, LP; and East Bay Community Development Corporation. Plaintiff was the owner of property located in Barrington. Plaintiff filed a complaint appealing the assessment of his property (tax appeal action) and filed a separate declaratory judgment action. In essence, Plaintiff argued that he was forced to pay a higher amount on his taxes because of Sweetbriar's favorable tax treatment under R.I. Gen. Laws 44-5-12 and 44-5-13.11. The hearing justice ruled that Plaintiff lacked standing to bring either action. The Supreme Court affirmed, holding (1) Plaintiff lacked standing to bring the declaratory judgment action; and (2) the hearing justice did not err in determining that Plaintiff lacked standing to challenge Barrington's application of section 44-5-12 and 44-5-13.11 to the Sweetbriar development, along with another project. View "Morse v. Minardi" on Justia Law

The Supreme Court quashed the order of the superior court denying Plaintiff’s motion for a protective order concerning the deposition of Lawrence Rainey, holding that, pursuant to rule 26(b)(4)(B) of the Superior Court Rules of Civil Procedure, Defendants failed to demonstrate “exceptional circumstances” to depose Rainey, a nontestifying expert.On appeal, Plaintiff argued that Rainey was a nontestifying expert and therefore may not be deposed absent a showing of exceptional circumstances in accordance with Rule 26(b)(4)(B). The Supreme Court agreed, holding (1) Rule 26(b)(4)(B) is applicable to the discovery issue here; (2) the hearing justice erred in failing properly to apply the Rule 26(b)(4)(B) standard in this case; and (3) Defendants failed to demonstrate “exceptional circumstances” as to why they wished to depose Rainey. View "Sandy Point Farms, Inc. v. Sandy Point Village, LLC" on Justia Law

The Supreme Court affirmed the judgment of the superior court granting Defendants’ motion to dismiss this action pursuant to Rule 41(b)(2) of the Superior Court Rules of Civil Procedure, holding that the motion justice did not abuse his discretion in dismissing the complaint.Plaintiff filed this action in 2010, but service was not completed at that time. In 2015, Plaintiff had copies of the complaint and summonses served upon Defendants. Defendants filed a motion to dismiss based on lack of prosecution and failure to serve process upon Defendants within the time required in Rule 4(1) of the Superior Court Rules of Civil Procedure. The motion justice dismissed the action, with prejudice, under Rule 41(b). The Supreme Court affirmed, holding that, given the five-year delay in serving the complaint and the lack of any explanation for the delay, the motion justice did not abuse his discretion in dismissing the complaint. View "Duffy v. Town of West Warwick" on Justia Law

At issue was whether Plaintiff was entitled to relief under Rule 60(b)(6) of the Superior Court Rules of Civil Procedure from an order directing him to remove a garage from his property.In 2014, the superior court ordered Plaintiff to remove a garage he built on his property that violated the setback requirements set forth in the Town of Tiverton’s zoning ordinance. Thereafter, the Town removed the garage from Plaintiff’s property and placed a lien on the property for $69,300 in fines imposed by a 2015 contempt order. In 2016, Plaintiff filed a motion to vacate the 2014 order. The trial judge denied the motion.The Supreme Court reversed, holding (1) because the superior court possessed subject matter jurisdiction to order Plaintiff to remove his garage, and because the granting of the 2014 order did not violate due process, the order was not void; but (2) the unique circumstances of this case and its procedural flaws presented a manifest injustice justifying relief from the operation of the order under Rule 60(b)(6). View "McLaughlin v. Zoning Board of Review of the Town of Tiverton" on Justia Law

The Supreme Court affirmed the judgment of the superior court dismissing Plaintiffs’ second amended complaint with prejudice, holding that the hearing justice did not err in dismissing the complaint.In their second amended complaint, Plaintiffs challenged the constitutionality of the statutory system for appointing magistrates to the Rhode Island Traffic Tribunal. Specifically, Plaintiffs claimed that they were due a refund of fines and costs that had previously been assessed by the Traffic Tribunal because Defendants’ conduct was unconstitutional. Plaintiffs further argued that Defendants had been unjustly enriched by levying those fines. Defendants moved to dismiss Plaintiffs’ complaint with prejudice pursuant to Rules 12(b)(1) and 12(b)(6) of the Superior Court Rules of Civil Procedure. The justice granted the motion. The Supreme Court affirmed, holding that Plaintiffs’ complaint failed to state a viable claim for relief as to Plaintiffs’ constitutional claim and that the complaint failed to allege the facts necessary to support the unjust enrichment claim. View "McKenna v. Guglietta" on Justia Law

The Supreme Court affirmed the order of the superior court granting the motions to dismiss filed by Defendants, Bank of America, N.A. (BOA) and EverBank Mortgage (EverBank), on Plaintiff’s complaint seeking monetary damages for breach of contract and breach of the implied covenant of good faith and fair dealing, as well as a preliminary injunction to stop a foreclosure.Plaintiff executed a mortgage on his property in favor of Mortgage Electronic Registration Systems, Inc. (MERS). The mortgage was later assigned to BOA. After the BOA informed Plaintiff that his mortgage was in foreclosure he filed a complaint alleging, inter alia, that the assignment of the mortgage was void and that Defendants had no standing to foreclose on his property. A federal court granted Defendants’ motion to dismiss. Thereafter, Plaintiff brought this complaint. Defendants filed motions to dismiss. The superior court found that res judicata warranted the granting of Defendants’ motions to dismiss. The Supreme Court affirmed, holding that res judicata applied. View "Goodrow v. Bank of America, N.A." on Justia Law

The Supreme Court vacated the judgment of the superior court granting a motion brought by Defendant, the State Public Defender’s Office, for judgment on the pleadings regarding Plaintiff’s employment discrimination claims.Plaintiff in this case filed two complaints. In Nugent I, Plaintiff appealed an arbitration decision concluding that the Public Defender’s Office acted wth just cause when it terminated Plaintiff’s employment. Judgment entered in favor of Defendant on the basis that Plaintiff lacked standing to challenge the arbitration decision in court. In Nugent II, Plaintiff alleged unlawful employment discrimination. Defendant moved for judgment on the pleadings, arguing that res judicata barred Plaintiff’s discrimination claims. The hearing justice granted the motion, and final judgment entered in favor of Defendant on all claims. The Supreme Court vacated the judgment in Nugent II, holding that Nugent I was not a final judgment for purposes of res judicata because the consideration of Nugent’s standing did not reach the merits of Nugent I, and therefore, Plaintiff was not barred from seeking redress for her discrimination claims raised in Nugent II. View "Nugent v. State" on Justia Law