Joseph Hall v. City of Newport
138 A.3d 814
| R.I. | 2016Background
- In 2003 RIPTA driver Leon Budlong alleged he was assaulted; over a year later he identified Joseph Hall and Hall was ultimately acquitted after trial.
- Budlong drove a route that passed the Halls’ Ruggles Avenue home ~32 times daily; the Halls alleged a long pattern of harassment by Budlong beginning in 2004.
- The Halls (through counsel and Mrs. Hall herself) sent multiple written complaints to RIPTA in 2005 describing harassment and requesting Budlong be removed from the route; RIPTA investigated and responded that route assignments are governed by the collective-bargaining agreement and advised contacting police.
- The Halls sued RIPTA in 2007 asserting negligent supervision/retention resulting in emotional distress and other harms; they filed affidavits detailing numerous alleged incidents involving a RIPTA vehicle.
- RIPTA moved for summary judgment (arguing no duty, no actionable incident, no damages); the Superior Court granted summary judgment and entered partial final judgment under Rule 54(b). The Supreme Court vacated that judgment and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether RIPTA owed a duty of care to the Halls regarding supervision/retention of Budlong | Halls: RIPTA had notice of repeated harassment from written complaints and thus owed a duty to investigate and prevent employee harassment | RIPTA: letters were generalized and did not put RIPTA on notice of specific dangerous uses of a RIPTA vehicle; no special duty existed | Court: RIPTA had a duty to exercise reasonable care to investigate and take action where warranted; letters put RIPTA on notice |
| Whether material factual disputes exist on breach, proximate cause, and damages such that summary judgment was improper | Halls: affidavits and exhibits describe repeated incidents and emotional distress (lost sleep), raising triable issues of breach, causation, and damages | RIPTA: Halls failed to show Budlong was unfit/incompetent or that RIPTA’s negligence proximately caused compensable injury | Court: Affidavits and RIPTA letter present "red flag" evidence; material factual disputes exist and summary judgment was improper |
| Whether collateral estoppel bars the Halls' claim against RIPTA | Halls: not addressed as primary defense | RIPTA: prior Superior Court injunction proceeding precludes relitigation | Court: Prior injunction order was not a final judgment on the merits; collateral estoppel does not apply |
| Whether the Halls waived the negligent-supervision theory by pleading a differently titled claim | Halls: claim substance is negligent supervision causing emotional harm regardless of label | RIPTA: Halls’ amended complaint labels differ and thus argument waived | Court: No waiver; substance controls over title, claim proceeds |
Key Cases Cited
- Welsh Manufacturing, Division of Textron, Inc. v. Pinkerton’s, Inc., 474 A.2d 436 (R.I. 1984) (recognizing employer liability to third parties for negligent supervision/retention of unfit employees)
- Rivers v. Poisson, 761 A.2d 232 (R.I. 2000) (affirming summary judgment for employer where it lacked notice and the employee’s duties did not require heightened supervision; distinguished on facts)
- Wyso v. Full Moon Tide, LLC, 78 A.3d 747 (R.I. 2013) (elements of negligence: duty, breach, causation, damages)
- Peerless Insurance Co. v. Luppe, 118 A.3d 500 (R.I. 2015) (summary judgment standard: no genuine issue of material fact and moving party entitled to judgment as a matter of law)
- Jessup & Conroy, P.C. v. Seguin, 46 A.3d 835 (R.I. 2012) (party opposing summary judgment bears burden of proving factual disputes by competent evidence)