A. Salvati Masonry Inc. v. Michael Andreozzi et al.

Summary

The Rhode Island Supreme Court affirmed a Superior Court judgment for Michael and Amy Andreozzi in a payment dispute concerning masonry and backyard patio work. The court held that the plaintiff failed to prove by a preponderance of the evidence which work fell outside the original subcontract and remained unpaid, and it deferred to the trial justice’s credibility determinations. The court also deemed inadequately developed arguments concerning book account, goods and services rendered, quantum meruit, unjust enrichment, and a mechanic’s lien waived.

Holdings

1. The trial justice did not clearly err or misconceive or overlook material evidence in finding that Salvati failed to prove that the Andreozzis owed it money for patio construction outside the original subcontract.
2. Salvati waived its arguments concerning its book-account, quantum-meruit, unjust-enrichment, and mechanic's-lien claims by failing to provide meaningful appellate development or identify specific error.

Questions Presented

1. Whether the trial justice clearly erred or misconceived or overlooked material evidence in finding that the Andreozzis did not owe Salvati money for patio construction outside the original Pariseault subcontract.
2. Whether Salvati adequately developed its arguments concerning its book-account, goods-and-services-rendered, quantum-meruit, unjust-enrichment, and mechanic's-lien claims, or waived those arguments under Rhode Island's raise-or-waive rule.

Disposition

affirmed