Gail M. McCormick v. Narragansett Improvement Company, Inc.

CourtSupreme Court of Rhode Island
DecidedMay 31, 2024
Docket2022-0324-Appeal.
StatusPublished

This text of Gail M. McCormick v. Narragansett Improvement Company, Inc. (Gail M. McCormick v. Narragansett Improvement Company, Inc.) 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
Gail M. McCormick v. Narragansett Improvement Company, Inc., (R.I. 2024).

Opinion

Supreme Court

No. 2022-324-Appeal. (KC 11-114)

(Dissent begins on Page 9)

Gail M. McCormick :

v. :

Narragansett Improvement : Company, Inc.

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

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

OPINION

Justice Long, for the Court. The plaintiff, Gail M. McCormick (plaintiff or

Ms. McCormick), appeals from a Superior Court order and judgment in favor of the

defendant, Narragansett Improvement Company, Inc. (defendant or NICO), in her

personal injury action for injuries sustained on May 29, 2010. Ms. McCormick

alleges that two different justices of the Superior Court erred: (1) by vacating a

November 18, 2011 entry of default against NICO, and (2) by denying the plaintiff’s

motion for a new trial following a seven-day jury trial in March 2022. This case

came before the Supreme Court pursuant to an order directing the parties to appear

and 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 -1- appeal without further briefing or argument. For the reasons stated herein, we vacate

the judgment and remand this matter for a hearing on the assessment of damages.

Facts and Procedural History

On May 29, 2010, plaintiff sustained personal injuries after she lost control of

her motorcycle when it struck one or more unguarded manhole covers in the road on

Wilbur Avenue in Cranston, Rhode Island. Ms. McCormick filed suit against

several defendants, including NICO, after she learned that the City of Cranston had

contracted with NICO to make repairs to Wilbur Avenue beginning on

May 17, 2010. 1 An authorized agent of NICO received service of the summons and

complaint on October 13, 2011, but NICO failed to file an answer or otherwise

appear in the matter. Default entered against NICO on November 18, 2011.

On March 29, 2013, NICO sought to vacate the entry of default and submitted

an affidavit from one of its employees, superintendent Kevin Dorsey, in support of

its motion. In the affidavit, Mr. Dorsey attested that NICO did not begin to perform

repairs on Wilbur Avenue until June 2, 2010. The affidavit was silent about the

circumstances that led to NICO’s delay in answering Ms. McCormick’s complaint.

1 The other named defendants in the original complaint include the City of Cranston, Allan Fung, in his capacity as mayor of Cranston, and Robert F. Strom, in his capacity as finance director. In 2013, plaintiff amended her complaint for the second time to include Garrity Asphalt Reclaiming, Inc., David Ventetuolo, individually and in his capacity as acting public works director at the time of the accident, and Ken Mason, individually and in his capacity as then-public works director. The plaintiff settled with the City of Cranston and Garrity Asphalt prior to trial. -2- At the hearing on NICO’s motion to vacate the entry of default, the hearing

justice asked counsel for NICO to explain the good cause for failing to timely

respond to the complaint. Defense counsel detailed NICO’s internal process for

relaying legal complaints to its insurer, Arbella Insurance Company (Arbella): Upon

learning that a complaint has been filed, NICO communicates with its agent, who in

turn transmits the complaint to Arbella. Defense counsel argued that, consistent with

the typical practice, NICO believed that Arbella was representing its interests in the

instant case. 2 Counsel for NICO also offered to supplement the record with an

affidavit explaining the reasons for NICO’s failure to plead or otherwise defend, but

the hearing justice indicated that he would accept counsel’s representations as

sufficient for the time being.

In arguing against NICO’s motion to vacate the entry of default, counsel for

plaintiff challenged NICO’s failure to present an affidavit to support its claim of

good cause, among other perceived shortcomings under Rule 55(c) of the Superior

Court Rules of Civil Procedure. 3 The hearing justice acknowledged plaintiff’s

2 The transcript of the hearing on the motion to vacate the entry of default reflects that counsel for Arbella was present as well. 3 Counsel for plaintiff also argued that Arbella was an agent of NICO by virtue of their insurance agreement and thus in a position to ensure no delay in answering Ms. McCormick’s complaint. Additionally, counsel for plaintiff emphasized that removing the default would substantially prejudice Ms. McCormick because the statute of limitations was set to run in five weeks’ time; consequently, plaintiff would be “left trying to find” the proper person or business to name as a defendant within a short window. -3- concerns, emphasizing that “it’s not necessarily enough to say the ball got dropped,

without explaining it.” The hearing justice questioned counsel for Arbella regarding

Arbella’s obligation to appoint defense counsel in a timely manner. Counsel for

Arbella surmised that the complaint was lost somewhere in Arbella’s system but

stated that he was not in a position to determine how or why no action was taken.

Following this colloquy, the hearing justice granted NICO’s motion to vacate the

entry of default.

A seven-day jury trial commenced on March 7, 2022. At trial, Ms.

McCormick presented evidence from multiple witnesses: she testified about her

recollection of the accident and the injuries she sustained; Richard Bernardo, the

director of public works for the City of Cranston in 2010, discussed the historic

floods in March 2010 that caused significant damage to Wilbur Avenue; Alan Davis,

an expert in accident reconstruction, testified about his conclusions regarding what

specifically caused Ms. McCormick’s accident; and Mr. Dorsey testified about the

conditions of Wilbur Avenue and whether he believed they constituted an

emergency. Ms. McCormick also presented witnesses who testified regarding the

damages involved in this case, including her son, neurological surgeon Michael Olin,

M.D., and economics and forensic economics expert Allan Feldman, Ph.D. NICO

presented two witnesses in its case-in-chief: John Corso, the highway superintendent

for the City of Cranston at the time of the accident, testified that it is the general

-4- obligation of the highway department to maintain the city’s roadways; and Scott

Lukas, Ph.D., an expert in psychopharmacology and toxicology, testified about the

level of impairment that Ms. McCormick would have experienced at the time of the

accident given her blood alcohol level.

At the conclusion of trial, the jury returned a verdict finding NICO not liable

for plaintiff’s accident-related injuries. Ms. McCormick subsequently moved for a

new trial, arguing that the jury’s verdict in favor of NICO was inconsistent with the

instructions to the jury regarding the duty of care owed by defendant and went

against the weight of the evidence elicited at trial. The trial justice heard and denied

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