Rhode Island – Case Law Wire

Rhode Island Appellate Procedure Civil Procedure

Supreme Court of Rhode Island

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

/ June 9, 2026

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.

Rhode Island Appellate Procedure Civil Procedure Personal Injury & Tort

Supreme Court of Rhode Island

Uncategorized

DeOliveira v. Trecaso — Trial Court Affirmed on All Eleven Error Claims; Deposition of Dismissed Defendant, Google Earth Photos, and Verdict Sheet Phrasing Each Upheld

/ June 9, 2026

The Rhode Island Supreme Court affirmed a defense verdict in a motor vehicle negligence case, rejecting all eleven error claims by the plaintiffs. Significant holdings address: the admissibility of a dismissed defendant’s video deposition under Rule 32; authentication of bare Google Earth photographs by lay witnesses with personal knowledge; the narrow scope of the empty chair doctrine as limited to identifiable available witnesses; and the adequacy of a verdict sheet that used “was negligent” language in a comparative fault framework.

Rhode Island Personal Injury & Tort professional-liability Real Estate

Supreme Court of Rhode Island

Uncategorized

Hurd v. H&H Real Estate (Hogan Associates) — Expert Testimony Required to Establish Real Estate Broker’s Standard of Care; Internet-Search Duty Question Not Within Common Knowledge

/ June 9, 2026

The Rhode Island Supreme Court affirmed summary judgment for a real estate brokerage, holding that the standard of care for screening prospective tenants—including whether a “basic internet search” is required in addition to a credit and criminal background check—is not within the common knowledge of laypeople and therefore requires expert testimony. Because the plaintiff was precluded from offering expert testimony after repeatedly failing to produce his expert for deposition, his negligence claim could not survive summary judgment.