Pawtucket Redevelopment Agency v. Patricia Brown

Summary

The Rhode Island Supreme Court affirmed a Superior Court judgment granting the Pawtucket Redevelopment Agency a new trial on Patricia Brown’s negligent-misrepresentation counterclaim and setting aside the jury’s damages award. The court dismissed the agency’s separate appeal as untimely and held that the trial justice properly evaluated the evidence, witness credibility, and lack of a rational basis for the counterclaim award.

Holdings

1. The Agency's appeal was untimely because its notice of appeal was filed outside Rule 4(a)'s twenty-day period, and the Supreme Court therefore declined to review the denial of the renewed motion for judgment as a matter of law.
2. Although Brown's notice of appeal incorrectly referred to a judgment entered on October 19, 2012, the notice adequately identified the order granting a new trial and setting aside the verdict on her counterclaim.
3. The Superior Court properly granted the Agency a new trial and set aside the jury verdict on Brown's counterclaim because the trial justice carefully weighed the evidence, assessed witness credibility, and determined that the damages award had no rational basis and was against the fair preponderance of the evidence.
4. Brown waived any challenge to the denial of her motion for judgment as a matter of law by failing to renew the motion at the close of the evidence or after the jury's verdict.

Questions Presented

1. Whether the Agency's appeal from the denial of its renewed motion for judgment as a matter of law was timely under Rule 4(a) of the Rhode Island Supreme Court Rules of Appellate Procedure.
2. Whether the Superior Court properly granted the Agency a new trial and set aside the jury verdict on Brown's negligent-misrepresentation counterclaim.
3. Whether Brown preserved any challenge to the denial of her motion for judgment as a matter of law by failing to renew that motion at the close of the evidence or after the verdict.

Disposition

affirmed