Bouchard v. Price

694 A.2d 670, 26 Media L. Rep. (BNA) 1321, 1997 R.I. LEXIS 154, 1997 WL 225135
CourtSupreme Court of Rhode Island
DecidedMay 5, 1997
Docket95-205-Appeal
StatusPublished
Cited by54 cases

This text of 694 A.2d 670 (Bouchard v. Price) is published on Counsel Stack Legal Research, covering Supreme Court of Rhode Island primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bouchard v. Price, 694 A.2d 670, 26 Media L. Rep. (BNA) 1321, 1997 R.I. LEXIS 154, 1997 WL 225135 (R.I. 1997).

Opinions

OPINION

LEDERBERG, Justice.

This case came before the Supreme Court on cross-appeals by the plaintiffs, Marie Bou-chard, in her capacity as beneficiary of the estate of Joan Heaton; Steven Garofalo, in his capacity as the administrator of the estate of Joan Heaton; Mary Lou Bouchard, Raymond Bouchard, and Gail Zakalis, in their capacities as the brother and sisters of Joan Heaton; and Nancy Mayer, General Treasurer of the State of Rhode Island, ex rel. the above-named plaintiffs; and by the defendant, Craig Price. The plaintiffs have appealed the dismissal of their claims for wrongful death, unjust enrichment, and relief under the so-called Slayer’s Act. The defendant has appealed the granting of the plaintiffs’ motion for summary judgment on their sole remaining count seeking a declaration that the defendant is subject to the Criminal Royalties Distribution Act of 1983. The Attorney General for the State of Rhode Island has intervened, pursuant to Rule 24(d) of the Superior Court Rules of Civil Procedure, to argue that the Criminal Royalties Distribution Act is constitutional.

Facts and Procedural History

On September 21, 1989, defendant, then aged fifteen, appeared before the Family Court and admitted sufficient facts to be adjudicated delinquent for the murders of Joan Heaton and her daughters, Jennifer and Melissa Heaton. See State v. Price, 672 A.2d 893, 894-95 (R.I.1996). On April 26, 1994, plaintiffs filed a complaint against defendant in the Superior Court in which they sought damages for wrongful death (counts 1 through 6), relief based upon a theory of unjust enrichment (count 7), a declaration that defendant was subject to the Criminal Royalties Distribution Act of 1983 (count 8), and a declaration preventing defendant from receiving any benefits or property as a result of the deaths of Joan, Jennifer, and Melissa Heaton (count 9).

Following a hearing on August 16, 1994, defendant’s motion to dismiss was granted in respect to all counts except count 8. On February 24,1995, plaintiffs’ motion for summary judgment was granted on the sole remaining count. Thereafter, judgment was entered, and the parties filed these cross-appeals.

Wrongful Death Claims

On appeal, plaintiffs contended that the trial justice erred in dismissing their wrongful-death claims on the grounds that the claims were barred by the statute of limitations. It is undisputed that plaintiffs brought their action for wrongful death against defendant more than four and one-half years after the deaths underlying their claims. Although G.L.1956 § 10-7-2 clearly provides that the statute of limitations in a wrongful-death action is three years, plaintiffs argued that the statute of limitations was tolled in this case. The plaintiffs have advanced two theories in support of their position.

[672]*672First, plaintiffs contended that defendant’s minority tolled the statute of limitations for wrongful death until three years after defendant reached the age of majority. The plaintiffs noted that, pursuant to G.L. 1956 § 9-1-19, the statute of limitations on civil actions does not run during a plaintiffs minority, and argued that, as a matter of “equity, symmetry and basic fairness,” the statute of limitations should also not run “against those who have causes of action against minors.” Section 9-1-19 provides an exception to the statute of limitations for disabled, including minor, plaintiffs in civil actions. The rationale for tolling the statute of limitations for a minor plaintiff is to safeguard the minor’s right to bring civil actions that accrue during his or her minority until he or she reaches the age of majority, at which time the individual may decide whether to pursue such claims. We are of the opinion that no such analogous purpose would be served by tolling the statute of limitations in respect to minor defendants.

Moreover, we have previously held that § 9-1-19 does not toll the statute of limitations in a wrongful-death action. Short v. Flynn, 118 R.I. 441, 446-48, 374 A.2d 787, 790 (1977). In Short, we stated that because a claim for wrongful death was unknown at common law, chapter 7 of title 10 of the Rhode Island General Laws, entitled “Death by Wrongful Act,” created an entirely new right of action that “cannot now be maintained except to the extent and in the manner provided in that Act.” Id. at 443, 374 A.2d at 788. Therefore, under our holding in Short, the tolling provisions of § 9-1-19 are not applicable to plaintiffs’ claims under the wrongful-death act.

Second, plaintiffs asserted that their wrongful-death claims were tolled diming defendant’s minority, while he was a “wayward” and “delinquent” minor within the exclusive, original jurisdiction of the Family Court. The Family Court has exclusive, original jurisdiction in proceedings “[cjoneerning any child residing or being within the state who is: (i) Delinquent; (ii) Wayward; (in) Dependent; (iv) Neglected; or (v) Mentally defective or disordered.” G.L.1956 § 14-1-5. A minor who is adjudicated delinquent remains within the Family Court’s jurisdiction until he or she reaches the age of twenty-one. Section 14-1-6. The intent of the Legislature in granting exclusive, original jurisdiction to the Family Court is “to preclude * * * attaching criminal responsibility to juvenile offenders for the doing of the criminal act and thereby to protect a child under the prescribed age by adjudging him [or her] a wayward or delinquent child rather than entering a judgment of conviction on the criminal complaint.” State v. Cook, 99 R.I. 710, 712, 210 A.2d 577, 579 (1965). Clearly, the purpose of the legislative grant of exclusive jurisdiction to the Family Court is to protect a delinquent juvenile from the adult criminal justice system, and not to shield such a juvenile from civil liability.

The plaintiffs also argued that the Family Court’s exclusive jurisdiction over defendant divested the Superior Court of jurisdiction to hear a civil claim against defendant during his minority. The plaintiffs’ assertion regarding the Superior Court’s lack of jurisdiction over a delinquent minor is undercut by legislation that recognizes the right of a crime victim to petition the Family Court to “divulge the name and address of the juvenile accused of committing the crime solely for the purpose of allowing the victim to commence a civil action against the juvenile and/or his parents to recover for damages sustained as a result of the crime.” Section 14 — 1-66. This Court has held that “[t]he clear legislative intent behind § 14-1-66 is to allow victims to recover, via a civil action, damages suffered at the hands of a juvenile offender.” Matter of Falstaff Brewing Corp., Re: Narragansett Brewery Fire, 637 A.2d 1047, 1050 (R.I.1994).

We are of the opinion, therefore, that plaintiffs were not precluded from filing a civil suit in Superior Court against defendant during his minority. Consequently, the trial justice properly dismissed plaintiffs’ wrongful-death claims on the grounds that they were barred by the statute of limitations.

Claim for Unjust Enrichment

The plaintiffs next contended that the trial justice erred by dismissing their claim [673]*673for unjust enrichment.

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Bluebook (online)
694 A.2d 670, 26 Media L. Rep. (BNA) 1321, 1997 R.I. LEXIS 154, 1997 WL 225135, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bouchard-v-price-ri-1997.