John H. Williams v. Elizabeth McDonough Noonan

Supreme Court of Rhode Island·Decided May 21, 2026·No. 2024-0228-Appeal.·Published

Opinion

Supreme Court

No. 2024-228-Appeal.

(KC 20-362)

John H. Williams et al. :

v. :

Elizabeth McDonough Noonan et al. :

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. 2024-228-Appeal.

(KC 20-362)

John H. Williams et al. :

v. :

Elizabeth McDonough Noonan et al. :

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

OPINION

Justice Robinson, for the Court. The plaintiffs,1 John H. Williams and Warwick Cove Marina, Inc. (the Marina), appeal from an April 2, 2024 final judgment in favor of the defendants, Attorney Elizabeth McDonough Noonan and the law firm Adler Pollock & Sheehan P.C. (Adler Pollock). The plaintiffs contend that the hearing justice erred in granting the defendants’ motion for summary

1 Throughout this opinion, we will use the term “plaintiffs” to refer collectively to Warwick Cove Marina, Inc. and John H. Williams in his capacity as president and sole stockholder of all shares of that corporation. However, the plaintiffs have not provided any evidence other than Mr. Williams’s own conclusory affidavit (which contradicts his prior deposition testimony) to support their assertion that Mr. Williams ever retained Attorney Noonan or her law firm to represent him personally. Accordingly, we do not view Mr. Williams as being a party to this case in his individual capacity. See Mruk v. Mortgage Electronic Registration Systems, Inc., 82 A.3d 527, 533 (R.I. 2013) (“This Court has made it clear that ‘conclusory assertions in an affidavit filed in opposition to a motion for summary judgment are inadequate to establish the existence of a genuine issue of material fact * * *.’”) (quoting Soave v. National Velour Corporation, 863 A.2d 186, 192 (R.I. 2004)).

judgment because “there were substantial facts presented in the verified complaint and the [plaintiffs’] affidavit to create material issues of fact” relative to the defendants’ statute of limitations argument. The plaintiffs also contend that the hearing justice’s “decision that there was no attorney-client relationship as it relates to Mr. Williams * * * was clearly wrong on that issue.” It is the plaintiffs’ further contention that, because “one can amend interrogatories prior to the time when decision is closed,” the hearing justice erred in ruling that there was no viable legal malpractice claim given that they had failed to present any expert testimony.

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 after carefully reviewing the record, we conclude that cause has not been shown and that this case may be decided without further briefing or argument.

For the reasons set forth in this opinion, we affirm the judgment of the Superior Court.

I

Facts and Travel

This is an action alleging legal malpractice (Count I) stemming from Attorney Noonan’s representation of the Marina in connection with various appeals concerning taxes allegedly due to the City of Warwick, Rhode Island (the City).

The Marina is the owner of certain property located in Warwick. According to the Verified Complaint, John H. Williams “is the president and sole stockholder of all shares of” the Marina. In 2008, by way of a written engagement letter, Mr. Williams retained another Adler Pollock attorney (not a defendant in this case) with respect to a dredging permit relative to certain property owned by the Marina. In 2010, during the course of that attorney’s representation of the Marina concerning the dredging permit and without entering into a separate written retainer agreement, Mr. Williams retained Attorney Noonan and Adler Pollock to provide legal services to represent the Marina in connection with an ongoing controversy with the City regarding various property taxes imposed by the City.

Some ten years later, the adequacy (vel non) of those legal services would be the subject of the instant case. 2 And as we explain infra, the hearing justice ultimately granted summary judgment on the basis of the pertinent statute of limitations—a ruling that we analyze and eventually sustain in Part IV of this opinion. Accordingly, it is not necessary for us to describe in detail the extensive professional efforts of Attorney Noonan to resolve the Marina’s tax issues. The existence of those efforts is undisputed. The contemporaneous discussions and

2 The defendants were retained by the Marina in 2010. The plaintiffs commenced this action on April 21, 2020. Final judgment in defendants’ favor was entered on April 2, 2024.

contacts between Mr. Williams and Attorney Noonan concerning those efforts are specifically alluded to in Mr. Williams’s deposition testimony.3 After defendants had represented the Marina for several years, most notably in the form of attempts by Attorney Noonan to reach a settlement agreement with the City, the Marina decided to seek different legal representation. In mid-December of 2016, Attorney Robert J. Caron was engaged to represent the Marina. On January 6, 2017, Attorney Caron sent a letter to Attorney Noonan and stated that he had been retained by Mr. Williams “to take over his property tax matters currently pending before the City of Warwick.” Thereafter, Attorney Noonan did not perform any further legal work relative to the Marina’s tax appeals. On February 15, 2017, Attorney Noonan tendered to Attorney Caron her files relative to the Marina’s tax issues.

Over three years later, on April 21, 2020, plaintiffs filed a two-count Verified Complaint in the Superior Court. In Count I, plaintiffs alleged that “the legal services provided by the Defendants were negligent and constituted legal malpractice” because “the Defendant [sic] negligently failed to act with a degree of competence necessary to zealously represent the interest of the Plaintiffs.” In a separate count (Count II), plaintiffs alleged: “The negligent representation and/or

3 It is noteworthy that, at one point in his deposition, Mr. Williams testified that, while Attorney Noonan’s efforts were ongoing, he reached the conclusion that “the homework” was not being done.

legal services provided to the Plaintiff [sic] by the Defendant [sic] are a breach of the terms and conditions of the contract between the parties.” 4 On November 9, 2023, after both parties had engaged in the discovery process, defendants filed a motion for summary judgment, in which they contended (1) that plaintiffs’ claims of negligence and legal malpractice were barred by the three-year statute of limitations established by G.L. 1956 § 9-1-14.3; (2) that Mr. Williams “lack[ed] standing to pursue a cause of action in his individual capacity[;]” and (3) that “the undisputed facts fail[ed] to support a claim for legal malpractice” because plaintiffs could not “establish duty or causation without an expert” and because the “[u]ndisputed evidence fail[ed] to demonstrate that Defendants fell below the requisite standard of care.”

In response, plaintiffs contended (1) that “[t]here [was] ample evidence that supports a showing that Plaintiff John H. Willaims [sic] had a contractual agreement with the Defendants[;]” (2) that “[t]here [was] no evidence in the record that supports Defendants’ contention” that “Plaintiffs were aware of the alleged malpractice of the

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