Sara Roman v. The City of Providence

CourtSupreme Court of Rhode Island
DecidedApril 8, 2025
Docket2024-0075-Appeal. and 2024-0120-Appeal.
StatusPublished

This text of Sara Roman v. The City of Providence (Sara Roman v. The City of Providence) 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
Sara Roman v. The City of Providence, (R.I. 2025).

Opinion

Supreme Court

No. 2024-75-Appeal. No. 2024-120-Appeal. (PC 20-8313)

Sara Roman :

v. :

The City of Providence 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, and Long, JJ.

OPINION

Chief Justice Suttell, for the Court. In these consolidated appeals, the

plaintiff, Sara Roman, appeals from two Superior Court judgments, the first in favor

of the defendants, the City of Providence, Shomari Husband in his capacity as

Treasurer for the City of Providence,1 and Harrison Peters in his capacity as

superintendent of Providence Public School District (collectively, the city), and the

second in favor of the defendant K. Scott Construction & Disposal, Inc. (K. Scott),

following the grant of each respective defendant’s motion for summary judgment.

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

1 Pursuant to Rule 25(d)(1) of the Superior Court Rules of Civil Procedure, Shomari Husband was automatically substituted for his predecessor after becoming the Treasurer for the City of Providence.

-1- 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

herein, we vacate the judgment of the Superior Court in favor of the city and affirm

the judgment of the Superior Court in favor of K. Scott.

I

Facts and Travel

The plaintiff filed a complaint in Providence County Superior Court on

December 1, 2020, alleging that she sustained injuries when she slipped and fell “on

untreated snow and ice on the premises” of Dr. Martin Luther King Jr. Elementary

School in Providence. She filed an amended complaint on June 15, 2021, alleging

three counts of negligence. In counts one and two, plaintiff alleged that the city

breached its duty to maintain the premises in a safe condition. In count three,

plaintiff alleged that K. Scott “entered into a contract” with the city on or about

February 12, 2019, “for the application of salt/sand and snow removal” at the school

and that K. Scott was negligent.

The City

On March 29, 2023, the city filed a motion for summary judgment and a

corresponding memorandum, asserting that it did not owe any duty to plaintiff at the

time she fell because, under the Connecticut Rule, a landlord or business invitor’s

duty to remove snow accrued only after the snow stopped and there was a reasonable

-2- opportunity to remove the hazardous condition.2 The city argued that it did not owe

a duty to clear the area at the time plaintiff allegedly fell because its duty arose only

after the snowfall ended and a reasonable time had passed.

The plaintiff filed an objection and supporting memorandum with exhibits.

At the outset of her memorandum, she indicated that, “[o]n February 8, 2019, the

weather rained 0.13 in precipitation. * * * The average temperature remained below

33 degrees out for February 9, 10, 11, and 12. * * * On February 12, the weather

rained 0.92 precipitation and dropped 3.3 inches in new snow.” She argued that the

city owed a duty of care under more than one theory. First, plaintiff argued that the

Connecticut Rule did not apply because she was not a business invitee or tenant.

According to plaintiff, the city owed a duty of care pursuant to the factors established

in Banks v. Bowen’s Landing Corp., 522 A.2d 1222 (R.I. 1987). Second, she argued

that, even if the Connecticut Rule applied, the city owed a duty because she slipped

on ice and a reasonable time had passed before the city treated the area. Third,

2 We note that this was the city’s second motion for summary judgment. The city’s first motion for summary judgment was filed on February 24, 2021. There, the city argued that it was not liable to plaintiff because the city had not been notified that snow and ice existed on the sidewalk pursuant to G.L. 1956 § 24-5-14, which it argued was a condition precedent. The plaintiff opposed the motion, arguing that § 24-5-14 did not apply because plaintiff slipped on ice that was not located on Camp Street or the sidewalk or, alternatively, there was a genuine issue of material fact as to whether the ice that plaintiff slipped on was on the sidewalk. A justice of the Superior Court denied this first motion for summary judgment after he determined as a matter of law that the area where plaintiff alleged that she slipped and fell was not covered by the notice requirements of § 24-5-14.

-3- plaintiff contended that the city owed a duty under the unusual circumstance

exception to the Connecticut Rule.

In support of their respective arguments, plaintiff and the city relied on

plaintiff’s deposition testimony, which provides:

“Q. Was it already snowing when you went to pick the kids up? “A. No. After I come out it start. “Q. Okay. When you fell, was there already snow on the ground? “A. No. “Q. So there was no snow when you fell? “A. It start -- it was, like, a little bit. Like, a little sprinkle (indicating). But when I got out, it was more on the floor; it was more snowing on the floor with the storm. “*** “Q. Do you know what you fell on? “A. Yes, in the ice. Ice. “*** “Q. So you said that the snowstorm was coming -- “A. Yes. “Q. -- and that there wasn’t much snow on the ground? “A. Yes, but -- but when I get out, it was a lot of snow outside already when I get out because the storm coming that day. “Q. So when you went to go pick up your kids, you, you get to the school, you go inside to pick up your kids. “A. Uh-huh. “Q. When you went inside, was there snow on the ground? “A. Yes. Uh-huh. “Q. How much? “A. I don’t remember how much. I don’t remember. It was light. “Q. Do you know how long it had been snowing for? “A. No. “Q. Could you still see the cement? “A. No. Uh-uh.

-4- “Q. Was there more than a couple of inches of snow? “A. It was -- it was covered in, in the ice already. “Q. Was it covered in ice or snow? “A. The snow. It covered in the snow. When I get out, it was more snow. “*** “Q. So had it been snowing for, like, more than an hour? “A. Yes. Uh-huh. “*** “Q. What caused you to fall? What did you fall on? “*** “A. The snow. “Q. Okay. How do you know it was the snow? “A. Because I see it. It was the snow.”

The plaintiff further testified, “It was covered in ice. It was all covered in ice.” The

questioning continued:

“Q. It was covered in ice? “A. Yes, when I fell. “Q. Did it have snow? “A. Yes. All that, yup.”

In addition to her deposition testimony, in her responses to interrogatories, plaintiff

said that she “slipped and fell on ice which was hidden/covered by snow.”

On August 8, 2023, a justice of the Superior Court (the first hearing justice)

delivered a bench decision and granted the city’s motion for summary judgment

pursuant to the Connecticut Rule. The parties did not argue at the hearing.

That same day, plaintiff filed a premature but valid notice of appeal.

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