Dunn's Corners Fire District v. Westerly Ambulance Corps et al.

Summary

The Rhode Island Supreme Court affirmed summary judgment declaring that Dunn’s Corners Fire District had no obligation to provide fire, rescue, or other services to property owned by BPF Realty, LLC. The court held that the Superior Court had subject-matter jurisdiction over the declaratory judgment action and that the Bradford Fire District was not an indispensable party. It also concluded that no genuine issue of material fact existed because a legislative enactment excluded the property from the Bradford Fire District and an unrebutted affidavit confirmed its exclusion.

Holdings

1. The Superior Court had subject-matter jurisdiction over the declaratory-judgment action. The absence of the Bradford Fire District did not deprive the court of subject-matter jurisdiction because Dunn's Corners, which had contractually assumed the Bradford Fire District's firefighting responsibilities, was the appropriate party to seek clarification of its own contractual obligations.
2. No genuine issue of material fact existed. The property was outside the Bradford Fire District, and Dunn's Corners therefore had no obligation to provide fire-fighting, rescue, or other services to the property based on its location.

Questions Presented

1. Whether the Superior Court had subject-matter jurisdiction to issue declaratory relief concerning Dunn's Corners' obligation to provide fire-protection services when the Bradford Fire District was not joined.
2. Whether a genuine issue of material fact existed as to whether the BPF property was located within the Bradford Fire District.

Disposition

affirmed