Harodite Industries, Inc. v. Warren Electric Corp.
2011 R.I. LEXIS 109
R.I.2011Background
- Harodite filed a mass tort complaint in Rhode Island Superior Court arising from a May 2002 Massachusetts oil-preheater incident; Warren Electric designed, manufactured, and installed the pre-heater assembly.
- Original complaint asserted counts for breach of warranties, contract, negligence, manufacturing/design defects, and declaratory judgment about warranty terms.
- Discovery revealed new information, including post-incident testimony and expert disclosures, leading Harodite to consider amendments.
- Harodite moved to amend on April 23, 2009, incorporating new theories (gasket centering, lack of a fail-safe, and failure-to-warn) based on 2009 deposition testimony.
- The Superior Court denied the motion on May 22, 2009, citing substantial changes to the case and potential prejudice; Harodite sought certiorari review.
- Rhode Island Supreme Court affirmed the denial and upheld the hearing justice’s choice-of-law ruling that Rhode Island law governs the statute of limitations for the proposed amended claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the denial of the motion to amend was an abuse of discretion | Harodite argues amendment justified by new discovery and late-breaking deposition testimony | Warren Electric contends delay was undue, prejudicial, and would require substantial new discovery | No abuse of discretion; denial upheld |
| Which statute of limitations applies to the proposed amended claims | Rhode Island law should apply under Rhode Island’s interest-weighing test | Massachusetts law should apply due to most significant relationship | Rhode Island law applies; ten-year Rhode Island statute governs the amended claims |
| Whether the proposed amendments relate back under Rule 15(c) | Amendments should relate back to original filing dates given discovery-based changes | Relating back would be inappropriate given new theories and late filing | Court did not reach issue as part of affirming denial; focus remained on prejudice and timing |
| Whether the failure-to-warn and design-alterations were timely and properly pleaded | New theories arose from discovery and deposition evidence | New theories should have been pleaded earlier or subjected to stricter scrutiny | Not treated as error in ruling; analysis upholds denial given prejudice and timing |
| Policy/precision of Rhode Island’s choice-of-law approach | Forum should apply its own procedural rules for limitations | Interest-weighing appropriately balances ties among jurisdictions | Court upheld Rhode Island approach; Rhode Island law governs the amended claims |
Key Cases Cited
- Woodward v. Stewart, 104 R.I. 290 (1968) (origin of interest-weighing approach in Rhode Island tort choice of law)
- Najarian v. National Amusements, Inc., 768 A.2d 1253 (R.I. 2001) (tort choice-of-law factors and significance of contacts)
- Cribb v. Augustyn, 696 A.2d 285 (R.I. 1997) (application of interest-weighing approach to statute of limitations)
- Medeiros v. Cornwall, 911 A.2d 251 (R.I. 2006) (liberal amendment policy under Rule 15; prejudice considerations)
- Weybosset Hill Investments, LLC v. Rossi, 857 A.2d 231 (R.I. 2004) (prejudice and timing in denial of amendments to pleadings)
- Barrette v. Yakavonis, 966 A.2d 1231 (R.I. 2009) (deference to trial court on motion to amend; abuse of discretion standard)
- Gongoleski v. City of Providence, 14 A.3d 218 (R.I. 2011) (contextual mention of standard of review in Rhode Island)