In re Estate of Glenn E. Griggs Patricia Griggs v. David Heal, the Limited Guardian for the Late Glenn E. Griggs In re Estate of Glenn E. Griggs, 63 A.3d 867

Guardianship and estate litigation over Glenn Griggs spanning 2000–2010, with appellants seeking to challenge a contempt-sanctions order.
Probate Court awarded temporary co-guardianship to Heal and Dan Griggs; appellants refused to disclose Griggs’s location.
In 2010 the Probate Court imposed about $447,000 in contempt sanctions against appellants.
Appellants filed claims and reasons of appeal in Superior Court in Jan 2011 but provided only the decision and reasons, not the record.
Superior Court granted sanctions execution and dismissed the appeals for failure to timely provide the probate record; appellants appealed to Rhode Island Supreme Court.
Supreme Court affirmed the Superior Court’s judgments citing insufficient record to perfect the appeal and limits on extending record deadlines.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the appeals were properly dismissed for failure to provide a proper record.	Griggs objected to record insufficiency and sought extension.	Record was incomplete; §33-23-1 requires substantial record to perfect appeal.	Yes; appeals affirmed despite missing transcript/record.
Whether §33-23-1(c) allows extending time for the entire record, not just transcripts.	Extension should cover entire probate record.	Extension applies only to transcripts, not to the entire file.	§33-23-1(c) applies to transcripts; did not permit extending the record deadline.
Whether the trial justice erred in dismissing the appeals without a complete record.	Record could be supplemented later with necessary documents.	Record was insufficient to perfect appeal; dismissal appropriate under Griggs I.	No error; dismissal affirmed due to lack of substantial record.
Whether the Probate Court had inherent authority to sanction and whether death of ward affected jurisdiction.	Sanctions and jurisdiction remain challengeable despite ward’s death.	Probate Court possessed authority; death did not negate sanctions.	Not reviewable on this record; affirmed due to lack of adequate record.

Griggs v. Estate of Griggs, 845 A.2d 1006 (R.I. 2004) (record perfection limits; substantial record required to perfect appeal)
Adams v. Christie’s, Inc., 880 A.2d 774 (R.I. 2005) (transcript necessity; risky to appeal without transcript)
Sentas v. Sentas, 911 A.2d 266 (R.I. 2006) (requirement to inform court of transcript status; duty to complete record)
Procopio v. PRM Concrete Corp., 711 A.2d 650 (R.I. 1998) (clerk transmits record when complete; limitations on extensions)
N & M Properties, LLC v. Town of West Warwick, 964 A.2d 1141 (R.I. 2009) (de novo review standard for questions of law (background))