Ralph Mangiarelli, Jr. v. Town of Johnston

CourtSupreme Court of Rhode Island
DecidedMarch 1, 2023
Docket22-28
StatusPublished

This text of Ralph Mangiarelli, Jr. v. Town of Johnston (Ralph Mangiarelli, Jr. v. Town of Johnston) 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
Ralph Mangiarelli, Jr. v. Town of Johnston, (R.I. 2023).

Opinion

March 1, 2023

Supreme Court

No. 2022-28-Appeal. (PC 16-5893)

Ralph Mangiarelli, Jr. :

v. :

Town of Johnston 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

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

OPINION

Justice Goldberg, for the Court. This case came before the Supreme Court

on December 1, 2022, pursuant to an order directing the parties to appear and show

cause why the issues raised in this appeal should not be summarily decided. The

plaintiff, Ralph Mangiarelli, Jr., appeals from an order of the Superior Court denying

his motion for a new trial following a jury verdict in favor of the defendants, the

Town of Johnston (town); Joseph Chiodo, in his capacity as Treasurer for the town;

Arnold Vecchione, in his capacity as Public Works Director for the town; and John

Joe, alias.1 On appeal, the plaintiff claims that the trial justice erred in denying his

1 Although a party named John Joe is referred to as John Doe at times, this individual was never identified at trial. Our references to defendants do not include John Joe. -1- motion for a new trial.2 For the reasons set forth herein, we affirm the judgment of

the Superior Court.

Facts and Travel

This is a slip-and-fall case. On July 28, 2016, plaintiff went to the Johnston

Town Hall to pay his tax bill. He parked in the visitors parking lot in the rear of the

town hall and made his way towards the building’s rear entrance. According to

plaintiff, he walked through the parking lot towards the building; and, as he was

stepping up onto the curb, tripped and fell onto a staircase that leads up to the

entrance of the building. The plaintiff testified that:

“[T]here’s a crosswalk to go into the new patio * * * and as I was walking up, it’s on an angle. And the crosswalk meets the angle, but it’s not straight. And as I took one step up on the patio, my second foot still was on the asphalt. When I took another step with my right foot, not realizing my foot caught the top of the curbstone, I shot towards the stairway going * * * up the stairway of the back of [t]own [h]all.”

As a result of his fall, plaintiff suffered a fractured wrist, injuries to his ribs, and

scrapes to an arm and leg. A town hall employee called 911; rescue personnel from

2 The procedural posture of this case is anything but smooth. Although plaintiff argues that the trial justice erred by denying his motion for a new trial and by granting defendants’ motion for judgment as a matter of law, we note that judgment entered on the jury’s verdict only, not by way of judgment as a matter of law. Furthermore, plaintiff appeals only from the denial of his motion for a new trial and not from the decision granting defendants’ motion for judgment as a matter of law. Therefore, we confine our analysis to the appropriateness of the trial justice’s denial of plaintiff’s motion for a new trial. -2- the Johnston Fire Department transported plaintiff to Our Lady of Fatima Hospital

in North Providence, where he received treatment for his injuries.3

Prior to plaintiff’s fall, in 2015, the rear entrance to the town hall had been

reconstructed. The project included the demolition of the preexisting sidewalk and

stairs, as well as the installation of a new ramp, stairs, handrail, sidewalk, and curb.

The plaintiff testified that his fall occurred during his first visit to the town hall after

the reconstruction had been completed. At the time, there was no yellow striping or

signage in place on or near the curb. However, the record discloses that the

construction was completed in accordance with all applicable codes.4 After the

incident, the town painted the edge of the curb yellow, and placed cones with signs

reading “step up” on the curb.

The plaintiff filed this action on December 22, 2016, alleging one count of

negligence. He claimed that defendants were “negligent in maintaining the

premises” of the town hall in a “clean, good and safe condition,” by failing to warn

invitees such as him of a “dangerous condition”—namely, an “uneven and unmarked

curbing” that lacked “any yellow highlighting or warning.” The plaintiff alleged

that, as a result of defendants’ breach, he sustained personal injuries and damages.

3 Before plaintiff left the town hall on a stretcher, a town employee was given his tax payment and plaintiff was mailed a receipt a few days later. 4 These codes include the Rhode Island State Building Code, the Rhode Island Fire Safety Code, and the ADA Standards for Accessible Design. -3- A jury trial on plaintiff’s negligence claim took place over the course of two

days on October 24 and October 25, 2019. During trial, plaintiff’s theory of the case

was that the town was negligent because the curb presented a dangerous condition

of which defendants failed to warn. At the conclusion of plaintiff’s case, defendants

moved for judgment as a matter of law pursuant to Rule 50 of the Superior Court

Rules of Civil Procedure, arguing that plaintiff had presented no evidence as to the

applicable standard of care or whether the existence of an angled curb constituted a

breach of the standard of care. According to defendants, expert testimony was

required to prove that the curb constituted a dangerous condition. The plaintiff

objected and proffered his own motion for judgment as a matter of law. He argued

that whether the angle of the curb constituted a dangerous condition was within the

ken of the average juror and therefore, expert testimony was not required. The trial

justice reserved her decision on the motions.

The defendants rested without presenting any evidence and renewed their

motion for judgment as a matter of law. The trial justice again reserved decision on

the motion. The trial justice then charged the jury, in relevant part:

“This is a negligence case, so let me say, generally, negligence is defined as the failure of one person, acting in a given set of circumstances, to exercise that degree of care for the safety, interest or property of another person that a reasonably prudent person would ordinarily exercise in the same or similar circumstances.

-4- “Breaking that down, in order to establish negligence, a plaintiff must prove the following: One, that the defendant owed the plaintiff a duty of care; two, that the defendant breached that duty; and, three, that the plaintiff suffered damages as a proximate result of defendant’s breach.

“* * * “In considering whether defendant owes a duty of care to plaintiff, you may consider the facts and circumstances of a particular case including the nature of the relationship and the nature of the transaction. “* * * “In this particular case -- we’re talking about these ideas of negligence -- it is the plaintiff’s claim that the Town of Johnston had a duty to maintain its premises[,] specifically the area immediately adjacent to Town Hall, in a clean, safe condition for the general public and anticipated invitees.”

The trial justice also read aloud to the jury the questions on the verdict form. The

verdict form included three questions:

“1.

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