LandingPartners v. Shiva — Appeal Dismissed for Failure to File Transcript; Pro Se Appellant Cannot Avoid Rule 10(b)(1) Even When Challenging Rulings of Law
The Rhode Island Supreme Court dismissed a pro se appellant’s appeal from an order quashing a deposition subpoena and granting a protective order because the appellant deliberately failed to file the hearing transcript under Rule 10(b)(1). The Court addressed the narrow exception allowing transcript-free appeals on pure legal questions but found a one-page order saying only “for reasons stated on the record” insufficient to permit meaningful review.