Estate of Louis Campagnone, By and through its Administrator, Dana Martinelli v. The State of Rhode Island

Supreme Court of Rhode Island·Decided March 10, 2026·No. 2024-0263-Appeal.·Published

Opinion

Supreme Court

No. 2024-263-Appeal.

(PC 15-5550)

Estate of Louis Campagnone, By and :

through its Administrator, Dana Martinelli

v. :

The State of Rhode Island. :

NOTICE: This opinion is subject to formal revision before publication in the Rhode Island Reporter. Readers are requested to notify the Opinion Analyst, Supreme Court of Rhode Island, 250 Benefit Street, Providence, Rhode Island 02903, at Telephone (401) 222-3258 or Email opinionanalyst@courts.ri.gov, of any typographical or other formal errors in order that corrections may be made before the opinion is published.

Supreme Court

No. 2024-263-Appeal.

(PC 15-5550)

Estate of Louis Campagnone, By and :

through its Administrator, Dana Martinelli

v. :

The State of Rhode Island. :

Present: Suttell, C.J., Goldberg, Robinson, Lynch Prata, and Long, JJ.

OPINION

Justice Long, for the Court. The plaintiff, the Estate of Louis Campagnone by and through its Administrator, Dana Martinelli (the Estate or plaintiff), appeals from an order and judgment of the Superior Court granting summary judgment in favor of the defendant, the State of Rhode Island (the state or defendant), in this negligence action involving a slip-and-fall accident in a bathroom at Scarborough South State Beach (Scarborough) in Narragansett, Rhode Island. 1 This case came before the Supreme Court pursuant to an order directing the parties to appear and

1 Mr. Campagnone filed the underlying complaint in this action. After he died of unrelated causes in 2022, his daughter and court-appointed administrator, Dana Martinelli, became his successor in interest in this case.

show cause why the issues raised in this appeal should not be summarily decided. After considering the parties’ written and oral submissions and reviewing the record, we conclude that cause has not been shown and that we may decide this case without further briefing or argument. For the reasons set forth in this opinion, we affirm the judgment of the Superior Court.

Facts and Procedural History The following facts are not in dispute. Scarborough is a public beach in Narragansett owned and operated by the state; the Department of Environmental Management (RIDEM) maintains the state’s parks and beaches. On August 31, 2014, Louis Campagnone entered the bathroom at Scarborough after spending the day with his family. Mr. Campagnone, who was using a cane, fell when his cane slipped as he walked into the bathroom. He sustained injuries to the left side of his body, including his hip, face, elbow, knee, shoulder, and ankle. After calling for aid, his nephews helped him up and out of the bathroom. Beach personnel called EMS, which transported him to South County Hospital, where doctors diagnosed him with a fractured hip.

Mr. Campagnone filed his complaint on December 21, 2015, alleging that he slipped and fell due to an accumulation of sand and water on the floor of the bathroom. As a result, he posited that the state breached its duty to him by (1) negligently allowing the bathroom to remain in a dangerous condition, (2) failing to

warn him of this dangerous condition, and (3) failing to clean or maintain the bathroom to avoid such a condition. He alleged that he suffered injuries, medical expenses, loss of enjoyment of life, and lost earning capacity as a direct and proximate result of this breach of duty. He sought compensation for his injuries and expenses.

After three years of discovery, defendant moved for summary judgment, asserting immunity from liability under Rhode Island’s Recreational Use Statute, G.L. 1956 chapter 6 of title 32 (RUS). The state argued that Mr. Campagnone did not demonstrate that RIDEM “willfully or maliciously failed to guard or warn against a known dangerous condition. In fact, the evidence demonstrates that RIDEM had no knowledge of any supposed ‘dangerous condition’ in the public restroom prior to plaintiff’s alleged accident.” The state also asserted immunity from liability under the public duty doctrine.

In support of this argument, the state cited the depositions conducted by plaintiff’s counsel of Roger Monfette, a regional manager with RIDEM, and Brendan Quigley, who worked as a park ranger at Scarborough in 2014. These individuals denied having any knowledge about any past injuries in the bathrooms at Scarborough.

In response, Mr. Campagnone asserted that there remained issues of fact as to whether the state breached its duty, thus triggering the exception to the RUS, and

that the public duty doctrine was inapplicable. In support, he relied in part on a Providence Journal article that discussed the unclean conditions in the bathrooms of Rhode Island’s state beaches and a 2018 RIDEM study on Rhode Island’s state parks.

A justice of the Superior Court heard arguments on the motion for summary judgment on November 20, 2019, and reserved her ruling to allow Mr. Campagnone time to conduct further discovery. After a nearly three-year delay resulting largely from the COVID-19 pandemic, plaintiff filed an additional memorandum in support of his objection to the state’s motion for summary judgment. The plaintiff attached to this memorandum a transcript of the deposition of Jennifer Ogren, an associate administrator within RIDEM; the beach operations manual for Rhode Island state parks; and emails from beach patrons from 2016 to 2020 lamenting the cleanliness of the bathrooms at Scarborough (none of which discussed injuries at the facilities). Ms. Ogren testified that she had no knowledge of any other incidents involving people slipping and falling in the bathrooms at Scarborough between 2014 and 2019. The trial justice heard arguments on the supplemental briefing in February 2023. She once again reserved her decision in order to review the materials further.

Mr. Campagnone died of unrelated causes in March of 2022; his attorneys moved to substitute his daughter and court-appointed administrator, Dana Martinelli, as his successor in interest on March 28, 2023. The plaintiff then filed an amended

complaint on April 18, 2023, which reflected the substitution of the Estate in place of Mr. Campagnone but is otherwise identical to the original complaint.

On November 21, 2023, the trial justice issued a bench decision granting the state’s motion for summary judgment. The justice noted that this Court has not limited the application of the RUS to natural occurrences, but rather has interpreted the statute to afford “broad immunity to landowners who open their land to the public free of charge for recreational use.” She observed that the evidence in this case does not involve any disputed issues of fact, so deciding this case on the state’s motion for summary judgment was appropriate. The key question, she posited, related to defendant’s duty of care, and whether the state had the requisite level of knowledge as to the alleged danger of sand and water on the bathroom floor so as to trigger the exception to the RUS. The trial justice concluded that plaintiff had failed to prove that the state had notice of a dangerous condition in the bathroom at Scarborough and thus was entitled to immunity under the RUS.

The trial justice emphasized that the focus of the RUS analysis is not on whether the landowner has theoretical knowledge about a dangerous condition, but rather “whether the defendant was put on notice of a specific dangerous condition and was required to take protective action as a result.” She concluded that the Estate failed to prove that the state had notice of this dangerous condition. Viewed in the light most favorable to plaintiff, the evidence in this case could be proof of general

notice of a potentially hazardous condition; but, in her view, this was not enough to overcome the presumption of immunity under the RUS. The trial justice did not reach the issue of whether the public duty doctrine applied.

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Estate of Louis Campagnone, By and through its Administrator, Dana Martinelli v. The State of Rhode Island, (R.I. 2026).

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