Dennis Martin, in his capacity as of the Estate of Camella L. Martin v. Michael Lawrence, alias
79 A.3d 1275
| R.I. | 2013Background
- Automobile collision at the Angell and Hope Streets intersection in Providence between Camella Martin and Michael Coyne in June 2006.
- Coyne allegedly drove left lane; he testified speed 30–32 mph and that light was green when he entered the intersection.
- Martin suffered multiple injuries; she died in 2008; Dennis Martin, executor, pursued the action in 2007.
- A key evidentiary issue was a document titled Notice of Injury—Proof of Loss prepared by Allstate, offered by plaintiff and excluded as hearsay.
- Trial court granted defendant’s in limine motion to exclude the document; jury returned a verdict for Coyne.
- Dennis Martin appealed challenging the evidentiary ruling and the denial of post-trial motions; the Supreme Court issued an affirmance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of Notice of Injury—Proof of Loss as hearsay | Martin argues Rule 803(6) and 803(24) authorize admission | Coyne contends it is inadmissible hearsay | Not admitted; ruling upheld that it did not fall within business-records or catchall |
| Judgment as a matter of law / new trial viability | Verdict inconsistent with evidence; Coyne failed to exercise reasonable care | Trial court properly weighed credibility and proximate cause | No reversal; trial court’s denial affirmed the jury verdict |
| Preservation of error for motion in limine ruling | Error preserved despite lack of explicit trial objection | Waiver; no preserved objection exists | Waiver; merits nonetheless reviewed, finding no abuse of discretion |
Key Cases Cited
- State v. Viveiros, 45 A.3d 1232 (R.I. 2012) (review of motions in limine and admissibility standard )
- State v. Scanlon, 982 A.2d 1268 (R.I. 2009) (hearsay and evidentiary rulings reviewed for abuse of discretion)
- Fravala v. City of Cranston, 996 A.2d 696 (R.I. 2010) (admissibility decisions subject to abuse-of-discretion review)
- Rhode Island Managed Eye Care, Inc. v. Blue Cross & Blue Shield of Rhode Island, 996 A.2d 684 (R.I. 2010) (Rule 803(6) business-records criteria and foundation)
- Medeiros v. Rhode Island Public Transit Authority, 712 A.2d 869 (R.I. 1998) (reliability requirements for business records)
- In re Steven D., 23 A.3d 1138 (R.I. 2011) (catchall Rule 803(24) confines use to exceptional circumstances)
- State v. Hallenbeck, 878 A.2d 992 (R.I. 2005) (preservation & objection requirements for evidentiary issues)
- Greensleeves, Inc. v. Smiley, 68 A.3d 425 (R.I. 2013) (raise-or-waive rule for evidentiary errors)