Yankee v. LeBlanc

Summary

The Rhode Island Supreme Court reviewed summary judgment in an indemnity and contribution action arising from an automobile collision on Old Angell Road. The court affirmed summary judgment for the Town of Cumberland on the defective roadway design claim under the public duty doctrine, but reversed summary judgment on the claim that the town breached its statutory duty to trim roadside vegetation because genuine issues of material fact remained regarding notice, breach, and causation.

Holdings

1. The public duty doctrine immunized the Town of Cumberland from liability on the LeBlancs' defective-design claim because the town's roadway-design and maintenance decisions were discretionary governmental actions and the evidence did not establish egregious conduct.
2. The public duty doctrine did not shield the town from the LeBlancs' claim that it breached its statutory duty to trim vegetation bordering the roadway.

Questions Presented

1. Whether the public duty doctrine immunized the Town of Cumberland from liability for the alleged defective design and maintenance of Old Angell Road.
2. Whether the town's conduct was sufficiently egregious to fall within the exception to public-duty immunity.
3. Whether the town owed and may have breached a statutory duty to trim vegetation bordering the roadway.
4. Whether disputed evidence concerning vegetation overgrowth, notice, and proximate cause precluded summary judgment.

Disposition

reversed_and_remanded