Greensleeves, Inc. v. Philip B. Smiley, Sr.
68 A.3d 425
R.I.2013Background
- Greensleeves, Inc. contracted with Smiley in 1995 to buy six Lee’s Wharf dock slips for $165,000, with closing to occur June 14, 1995.
- Smiley instead sold the same slips to Friedrich for $175,000, with a $20,000 cash deposit, and refused to close with Greensleeves.
- Greensleeves sued for specific performance; Friedrich intervened and the trial court initially dismissed, but this Court later held an enforceable Greensleeves–Smiley contract existed.
- On remand, Greensleeves prevailed on tortious interference of contract; the trial court awarded Greensleeves $61,258.05 in lost rent plus prejudgment interest and costs.
- The Superior Court later denied Friedrich’s Rule 59(e) motion to reduce prejudgment interest; Friedrich timely appealed.
- This Court affirms the judgment, finding no reversible error in the trial court’s ruling on liability or prejudgment interest.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did Friedrich tortiously interfere with Greensleeves–Smiley contract? | Greensleeves argues interference was intentional and improper and caused damages. | Friedrich asserts lack of improper interference and challenges trial findings. | Yes; intentional, improper interference supported by evidence and credibility findings. |
| Was the prejudgment-interest award properly denied reduction under Rule 59(e)? | Greensleeves contends the award fairly compensates delay in payment. | Friedrich argues delay due to appeals warrants reduction. | No manifest legal error; denial of relief affirmed. |
Key Cases Cited
- Belliveau Building Corp. v. O'Coin, 763 A.2d 622 (R.I. 2000) (elements and factors for tortious interference and address of improper interference)
- Greensleeves, Inc. v. Smiley, 694 A.2d 714 (R.I. 1997) (valid contract for dock slips; enforceability; law of the case)
- Greensleeves II, 942 A.2d 284 (R.I. 2007) (remanded for tortious interference analysis; Bissonnette rule discussed)
- Avilla v. Newport Grand Jai Alai LLC, 935 A.2d 91 (R.I. 2007) (motive and improper means in tortious interference; Noerr-Pennington context noted)
- Pusyka, 592 A.2d 850 (R.I. 1991) (prior inconsistent statements as substantive evidence)