Kimberly Lomastro v. Margaret Iacovelli et al.

Summary

The Rhode Island Supreme Court reviewed a Superior Court judgment granting summary judgment to municipal defendants in a wrongful-termination action brought by a school-bus driver. The Court held that the trial justice abused his discretion by denying the plaintiff leave to amend her complaint to assert tortious interference without making sufficient findings concerning prejudice, delay, bad faith, futility, or other grounds. The Court vacated the summary judgment and remanded for a hearing on the motion to amend.

Holdings

1. A motion to amend must be freely granted when justice so requires, absent a legally sufficient reason such as undue delay, bad faith, repeated failure to cure deficiencies, undue prejudice, futility, or another compelling justification. The trial justice's bare concern that amendment would be unfair because the proposed claim was prompted by the court's comments was insufficient, and the denial without specific findings or an adequate opportunity for briefing and argument was an abuse of discretion.
2. The Superior Court's grant of summary judgment was vacated and the case was remanded for further proceedings concerning Lomastro's motion to amend and defendants' objection.

Questions Presented

1. Whether the Superior Court properly granted summary judgment on Lomastro's wrongful-termination claim because no employer-employee relationship existed between Lomastro and the Town of Johnston.
2. Whether the Superior Court abused its discretion by denying Lomastro leave to amend her complaint to add a claim for tortious interference with a contractual relationship.

Disposition

reversed_and_remanded