Patnaude v. Brown, 2004-0201 (2004)

CourtSuperior Court of Rhode Island
DecidedSeptember 3, 2004
DocketC.A. No. WC 2004-0201
StatusUnpublished

This text of Patnaude v. Brown, 2004-0201 (2004) (Patnaude v. Brown, 2004-0201 (2004)) is published on Counsel Stack Legal Research, covering Superior 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
Patnaude v. Brown, 2004-0201 (2004), (R.I. Ct. App. 2004).

Opinion

[EDITOR'S NOTE: This case is unpublished as indicated by the issuing court.]

DECISION
Before this Court is Defendants' motion to dismiss pursuant to Super. R. Civ. P. 12(b)(6). This Court heard oral arguments on the motion on August 16, 2004.

Facts and Travel

On Febuary 27, 2001, Plaintiff, John Patnaude, entered into a purchase and sales agreement with the owners of real estate located at 613 Aquidneck Avenue, Middletown, Rhode Island The agreement was contingent upon the property being zoned for automobile sales and service.1

On March 26, 2001, Mr. Patnaude visited the Middletown building/zoning official, Jack Maloney, and presented a written request for confirmation that the property was a grandfathered nonconforming use which could be used for automobile sales and service. The request notified Mr. Maloney that Mr. Patnaude intended to purchase the property and use it for an automobile sales and service center. On that same date, Mr. Maloney responded in writing to Mr. Patnaude's request, and opined that the "use of the property as a `used car' dealership would be allowed as a preexisting nonconforming use."

Mr. Patnaude closed on the property on April 6, 2001. After the sale, Mr. Patnaude began renovating the property. Shortly thereafter, an abutter to the property appealed the zoning certificate issued by Mr. Maloney to the Middletown Zoning Board of Review (hereinafter Zoning Board). After a hearing, the Zoning Board reversed Mr. Maloney's determination and found that the prior use as a used car dealership had been abandoned by the previous owner.2 In particular the Zoning Board found that the abandonment occurred in 1979 as a result of the previous owner's petition for a use variance to change the use of the property from a used car dealership to light industry. The Zoning Board granted that petition, and the previous owner was also granted an electrical permit to conduct changes to the building.

Mr. Patnaude was unable to conduct business on the property as a result of the Board's decision, and thus, was unable to pay the mortgage. The previous owners, Mr. and Mrs. Alofsin, who held the mortgage on the property, responded by foreclosing on the mortgage.

On March 26, 2004, the Plaintiff filed the present complaint.3 The Plaintiff alleges that Mr. Maloney, acting within the scope of his authority as the Town of Middletown Building/Zoning Official intentionally and/or negligently failed to consider documents under his control, or at his disposal, when he provided the Certificate of Zoning Compliance to the Plaintiff. Specifically, Plaintiff avers that Mr. Maloney failed to perform due diligence and exercise due and reasonable care with regards to the factual basis for the Certificate of Zoning Compliance issued by him.

Standard of Review

In determining whether to grant a Rule 12(b)(6) motion to dismiss, this Court "assumes the allegations contained in the complaint to be true and views the facts in the light most favorable to the plaintiffs." Giulianov. Pastina, Jr., 793 A.2d 1035, 1036-37 (R.I. 2002) (quoting Martin v.Howard, 784 A.2d 291, 297-98 (R.I. 2001)). This Court should not grant the motion "unless it appears to a certainty that [the plaintiffs] will not be entitled to relief under any set of facts which might be proved in support of [their] claim." Id. at 1037 (quoting Bragg v. Warwick ShoppersWorld, Inc., 102 R.I. 8, 227 A.2d 582, 584 (R.I. 1967)). "The standard for granting a motion to dismiss is a difficult one for the movant to meet." Diciantis v. Wall, 795 A.2d 1121 (R.I. 2002).

In its motion to dismiss, the Defendants aver that the Plaintiff is merely seeking damages based on his reliance on the zoning certificate. The Defendants submit two reasons why they believe the Plaintiff's claim must fail. First, the Defendants aver that the case of Tompkins v. ZoningBd. Of Review of the Town of Little Compton, 2003 WL 22790829, C.A. No. NC2001-204 (R.I. Super 2003), makes clear that a zoning certificate does not vest any rights in Plaintiff. Second, the defendants aver that Plaintiff's present claim is not ripe because of his pending appeal of the Zoning Board's Decision.

As to the Defendants' first contention, this Court notes that the Plaintiff is not appealing the issuance of or the information contained in the zoning certificate. That issue will be addressed, or dismissed under the rationale of Tompkins, in the pending appeal of the Zoning Board's decision. This Court is concerned with the present action — the alleged intentional or negligent acts or omissions of the Building/Zoning Official.

Section 9-31-1(a) provides that

[t]he state of Rhode Island and any political subdivision thereof, including all cities and towns, shall, subject to the period of limitations set forth in § 9-1-25, hereby be liable in all actions of tort in the same manner as a private individual or corporation; provided, however, that any recovery in any such action shall not exceed the monetary limitations thereof set forth in this chapter.

According to the public-duty doctrine, Rhode Island governmental entities enjoy immunity from tort liability arising out of their discretionary governmental actions that by their nature are not ordinarily performed by private persons. Haley v. Town of Lincoln,611 A.2d 845, 849 (R.I. 1992). The Rhode Island Supreme Court has, however, established definite limitations on the immunity of government.See generally Verity v. Danti, 585 A.2d 65 (R.I. 1991). Liability will not attach "absent proof that a special duty is owed to the plaintiff as an individual rather than as a member of the general public."4 Id. at 66.

In cases in which courts have acknowledged the existence of a special duty, the plaintiffs have had some form of prior contact with state or municipal officials "who then knowingly embarked on a course of conduct that endangered the plaintiffs, or they have otherwise specifically come within the knowledge of the officials so that the injury to that particularly identified plaintiff can be or should have been foreseen."Quality Court Condominium Ass'n v. Quality Hill Dev. Corp., 641 A.2d 746, 750 (R.I. 1994) (citing Knudsen v. Hall, 490 A.2d 976, 978 (R.I. 1985)).5

At the outset we note that the activities — record keeping and the issuance of the zoning certificate6

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Related

DiCiantis v. Wall
795 A.2d 1121 (Supreme Court of Rhode Island, 2002)
Giuliano v. Pastina
793 A.2d 1035 (Supreme Court of Rhode Island, 2002)
Verity Ex Rel. Verity v. Danti
585 A.2d 65 (Supreme Court of Rhode Island, 1991)
Rhode Island Ophthalmological Society v. Cannon
317 A.2d 124 (Supreme Court of Rhode Island, 1974)
Quality Court Condominium Ass'n v. Quality Hill Development Corp.
641 A.2d 746 (Supreme Court of Rhode Island, 1994)
Kuzniar v. Keach
709 A.2d 1050 (Supreme Court of Rhode Island, 1998)
Palazzolo v. State Ex Rel. Tavares
746 A.2d 707 (Supreme Court of Rhode Island, 2000)
Bragg v. Warwick Shoppers World, Inc.
227 A.2d 582 (Supreme Court of Rhode Island, 1967)
Knudsen v. Warner
490 A.2d 976 (Supreme Court of Rhode Island, 1985)
Martin v. Howard
784 A.2d 291 (Supreme Court of Rhode Island, 2001)
Haley v. Town of Lincoln
611 A.2d 845 (Supreme Court of Rhode Island, 1992)

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Bluebook (online)
Patnaude v. Brown, 2004-0201 (2004), Counsel Stack Legal Research, https://law.counselstack.com/opinion/patnaude-v-brown-2004-0201-2004-risuperct-2004.