Rodriguez v. Providence Housing Authority

Summary

The Rhode Island Supreme Court affirmed summary judgment for the Providence Housing Authority in a wrongful-death action arising from an elderly tenant's fatal fall on an apartment staircase. The court held that the Housing Authority owed no duty to provide a transfer to a single-story apartment or alternative accommodations because the stairs were not defective and the apartment was fit and habitable.

Holdings

1. The Housing Authority owed no duty to search its other housing complexes or provide an alternative remedy such as a hospital bed or portable toilet when no suitable single-story apartment was available and the existing apartment was fit and habitable.
2. Summary judgment was proper because the material facts were undisputed and the Housing Authority was entitled to judgment as a matter of law.

Questions Presented

1. Whether the Providence Housing Authority owed the decedent a duty to transfer the family to a single-story apartment or provide an alternative accommodation after learning of his prior fall.
2. Whether summary judgment was proper where the apartment was fit and habitable and the staircase was not defective.

Disposition

affirmed