Arinola Olawuyi v. Ferland Property Management

Summary

The Rhode Island Supreme Court affirmed the Superior Court’s judgment for Ferland Property Management. The Court held that the plaintiffs’ alleged privacy and personal-injury claims were barred by Rhode Island’s three-year statute of limitations, and it also agreed that the illegal-eviction claim was precluded by prior litigation. The claims asserted on behalf of the minor children had been dismissed without prejudice after the plaintiffs failed to obtain counsel.

Holdings

1. The adult plaintiffs' claims were untimely under the three-year statute of limitations for personal injuries because any alleged injuries occurred in or about 2012, while the complaint was not filed until March 27, 2024.
2. Summary judgment was properly granted because, viewing the admissible evidence in the light most favorable to the plaintiffs, no genuine issue of material fact existed and the defendant was entitled to judgment as a matter of law.
3. The Superior Court correctly ruled on issue-preclusion grounds with respect to the plaintiffs' illegal-eviction allegation.
4. The dismissal without prejudice of the minor children's claims did not warrant reversal; the children remained free to pursue their claims through an attorney or to proceed pro se after reaching the age of majority.

Questions Presented

1. Whether the adult plaintiffs' personal injury and invasion-of-privacy claims were barred by Rhode Island's three-year statute of limitations.
2. Whether the plaintiffs' illegal-eviction claims were barred by issue preclusion or res judicata because the eviction-related issues had already been litigated in the District Court.
3. Whether the Superior Court properly dismissed the minor children's claims without prejudice after the plaintiffs failed to obtain counsel to represent them.

Disposition

affirmed