Oberlander v. General Motors Corp.

Summary

The Rhode Island Supreme Court affirmed summary judgment for General Motors in a breach-of-warranty action involving an allegedly defective pickup truck. The court held that the law-of-the-case doctrine did not prevent the Superior Court from independently reconsidering the summary-judgment motion after a de novo appeal from the District Court. The court concluded that the plaintiff failed to provide competent evidence that the truck was defective when sold, that the defect was attributable to General Motors, or that he suffered damages.

Holdings

1. The law-of-the-case doctrine did not bar the Superior Court from independently ruling on General Motors's summary-judgment motion because the motion was heard in a different court. A trial de novo in the Superior Court permits an independent determination of questions of law and fact.
2. Summary judgment was proper because the plaintiff failed to present competent evidence establishing a genuine issue of material fact concerning whether the truck was defective when it left the seller's hands, whether any defect was attributable to General Motors, or whether the plaintiff suffered damages.

Questions Presented

1. Whether the law-of-the-case doctrine barred the Superior Court from independently deciding General Motors's summary-judgment motion after the District Court had previously denied a substantially similar motion.
2. Whether the Superior Court improperly resolved factual issues rather than merely determining whether genuine issues of material fact existed.
3. Whether summary judgment was proper where the plaintiff offered no competent evidence that the truck was defective when it left the seller's control, that a defect was attributable to General Motors, or that he suffered damages.

Disposition

affirmed