Credit Union Central Falls v. Groff

Summary

The Supreme Court of Rhode Island held that Doris P. Riendeau was entitled to intervene under Superior Court Rule of Civil Procedure 24(a)(2) in Credit Union Central Falls’ action against Lawrence S. Groff. Riendeau claimed a particularized interest in funds held in Groff’s client trust account, and the court concluded that existing parties did not adequately represent her competing claim. The court also held that a supplemental order preserving notice and a future hearing did not moot the appeal, reversed the denial of intervention, vacated the judgment, and remanded.

Holdings

1. Riendeau was entitled to intervene as of right because she claimed a particularized interest in the specific funds attached in the action, disposition of the action could impair or impede her ability to protect that interest, and the existing parties did not adequately represent her competing claim.
2. The appeal was not moot because the supplemental order did not deprive Riendeau of a continuing stake in the controversy and did not provide a sufficiently definite substitute for party status and discovery needed to protect her claim.

Questions Presented

1. Whether Riendeau was entitled to intervene as of right under Superior Court Rule of Civil Procedure 24(a)(2) because she claimed a specific interest in the attached client trust-account funds, disposition of the action could impair her ability to protect that interest, and existing parties did not adequately represent her interests.
2. Whether the Superior Court's supplemental order providing notice and a future hearing for potential claimants rendered the intervention appeal moot.

Disposition

reversed_and_remanded