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Rhode Island Supreme Court affirmed lower court decision, holding that plaintiffs were not entitled to disgorgement payments or punitive damages on usurious loans because they failed to meet statutory requirements under G.L. 1956 § 6-26-4(c), and affirmed summary judgment on stayed counts.
This case is one of two companion cases issued today. The first case is set forth in Commerce Park Realty, LLC v. HR2-A Corp., No. 19-468-A., in which certain defendants appealed a Superior Court declaration that a series of loans made by those defendants carrying interest rates ranging from 23 percent to 36 percent per annum were usurious and null and void. This case is a cross-appeal filed by certain plaintiffs seeking review of secondary determinations made by the Superior Court that coincided with the finding that the loans were usurious. On appeal, the plaintiffs assigned four claims of error: (1) the trial justice erred in concluding that they were not entitled to disgorgement payments on certain usurious loans under G.L. 1956 § 6-26-4(c) (2) the trial justice erred in dismissing their claims for punitive damages concerning certain usurious loans (3) the trial justice erred in allowing defendants to seek and obtain summary judgment on counts that were previously stayed and (4) the trial justice misapplied the statute of limitations to plaintiffs' claims for criminal usury under G.L. 1956 § 9-1-2. The Supreme Court held that, under the clear and unambiguous language set forth in § 6-26-4(c), these plaintiffs were not entitled to disgorgement payments because they did not make a payment on the usurious loan. Next, the Court determined that, because these plaintiffs did not meet the requirements set forth in § 6-26-4(c) to recover disgorgement payments, their claims for punitive damages failed as a matter of law. The Supreme Court then concluded that, although the trial justice's ruling on the stayed counts may not have been the best practice, any potential procedural error was harmless in consideration of practicality and judicial economy because a reversal of the trial justice's decision on those counts would only result in undue delay and expense in litigating legally unsustainable claims. Lastly, the Supreme Court held that these plaintiffs' claims under § 9-
This summary was generated to explain the ruling in plain English and is not legal advice.
The plaintiff, Clifton Peasley (plaintiff or Peasley), appealed the Superior Court's dismissal of his action for declaratory relief, which sought, inter alia, a decree that he was entitled to back pay. The Supreme Court affirmed the dismissal pursuant to the election of remedies doctrine. In this respect, it was undisputed that before commencing the action for declaratory relief, the plaintiff had filed a grievance seeking back pay, which proceeding remained pending in arbitration. Peasley's efforts to compare the provisions of the Teachers' Tenure Act with the landmark antidiscrimination protections discussed in Weeks v. 735 Putnam Pike Operations, LLC, 85 A.3d 1147 (R.I. 2014), was unavailing. The judgment of the Superior Court was affirmed.
The plaintiff, Jane Doe, appealed from a Superior Court judgment dismissing her complaint against the defendants, Brown University and two of its employees. In Superior Court, the plaintiff asserted claims under both the Rhode Island Civil Rights Act (RICRA) and article 1, section 2 of the Rhode Island Constitution. On appeal, the plaintiff argued that the hearing justice erred in determining that her claims under RICRA were precluded by the prior dismissal of the plaintiff's federal Title IX claim. The plaintiff also argued that the hearing justice erred in holding that section 2 of article 1 of the Rhode Island Constitution does not grant the plaintiff a private right of action. The Supreme Court first held that the plaintiff's claims under RICRA were predicated upon the defendants' alleged violations of Title IX, which had already been litigated in federal court. Further, the Supreme Court stated that the resolution of that issue in federal court was essential to the judgment on the merits and, therefore, issue preclusion barred the plaintiff's claim in Superior Court. The Supreme Court also held that the plaintiff's claim that the defendants interfered with her contract with an educational institution was not actionable. Next, the Supreme Court examined the antidiscrimination clause contained in section 2 of article 1 of the Rhode Island Constitution and held that it was not self executing. Further, the Supreme Court held that principles of judicial restraint prevented the Court from creating a private right of action under these circumstances. Accordingly, the Supreme Court affirmed the judgment of the Superior Court.
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