RICO Corporation v. Town of Exeter

Summary

The Supreme Court of Rhode Island affirmed the Superior Court's denial of RICO Corporation's motion to amend its complaint after remand and its entry of judgment for the Town of Exeter without a trial. The court held that the proposed equitable-estoppel and selective-enforcement claims exceeded the scope of the prior remand and that RICO had effectively conceded the factual issue concerning whether its predecessor held a license for the earth-removal business before May 2, 1977. Because the predecessor lacked the required lawful use, no valid preexisting nonconforming use could have been conveyed to RICO.

Holdings

1. The Superior Court did not abuse its discretion in denying RICO's motion to amend because the proposed claims fell outside the limited scope of the Supreme Court's remand and were untimely and potentially prejudicial.
2. The Superior Court properly entered judgment for Exeter without a trial because RICO effectively conceded that LaCroix had not obtained a license during the relevant 1973-to-1977 period, thereby resolving the only factual issue identified in the remand.
3. A lower court on remand must implement both the letter and spirit of the appellate mandate and may not disregard or expand the mandate's explicit directives.

Questions Presented

1. Whether the Superior Court abused its discretion by denying RICO's motion to amend its complaint on remand to add equitable-estoppel and selective-enforcement claims.
2. Whether the Superior Court erred by entering judgment for Exeter without conducting the evidentiary trial ordered by the Supreme Court.
3. Whether the trial court properly adhered to the limited scope of the Supreme Court's remand mandate.

Disposition

affirmed