Summary
The Supreme Court of Rhode Island held that Massachusetts negligence law governed a premises-liability action arising from an injury at a Massachusetts cinema. Applying Massachusetts comparative-negligence law, the court concluded that the plaintiff's 60 percent negligence barred recovery, sustained the defendants' appeal, vacated the Superior Court judgment, and remanded for entry of judgment for the defendants.
Topics
Practice areas
Questions Presented
- Whether Rhode Island or Massachusetts negligence law governed the premises-liability claim arising from an injury at the defendants' Massachusetts cinema.
- Whether the plaintiff's appeal from denial of her motion for additur should be granted.
Holdings
- Massachusetts negligence law governs because Massachusetts has the most significant relationship to the injury, the allegedly negligent conduct, the premises, and the parties' relationship.
- Because Andersen was found more than 50 percent negligent, Massachusetts law barred recovery against the defendants.
Key quotations
“Applying these factors to the case at bar, we conclude that the trial justice erred in not applying Massachusetts negligence law.” (1255)
“In sum, we conclude that Massachusetts has the most significant interest in this case, and therefore Massachusetts law should apply.” (1255)
“As a result, because Andersen was found more than 50 percent negligent, on the basis of Massachusetts law, damages from the defendants cannot be recovered.” (1256)
Factual background
In July 1994, Hope Andersen, a Rhode Island resident, attended a matinee at the defendants' cinema in Seekonk, Massachusetts. The theater was allegedly extremely dark, and Andersen, believing there was a wall beside her, reached out to steady herself and fell where no wall existed, fracturing her hip and elbow. The jury found the defendants 40 percent negligent and Andersen 60 percent negligent.
Procedural history
Hope Andersen's estate brought a negligence action after Andersen was injured at a Massachusetts cinema operated by the defendants. The jury found Showcase 40 percent negligent and Andersen 60 percent negligent and awarded damages reduced to Andersen's comparative share. The Superior Court denied the defendants' motion for a new trial and the plaintiff's motion for additur. The Supreme Court of Rhode Island sustained the defendants' appeal, denied the plaintiff's additur appeal, vacated the judgment, and remanded for entry of judgment for the defendants under Massachusetts law.
Remand instructions
The case was remanded to the Superior Court with directions to enter judgment for the defendants based on application of Mass. Gen. Laws Ann. ch. 231, § 85.