Michael J. Salvatore v. Thomas A. Palangio, 18-92

From 2005–2015 Salvatore made payments exceeding $170,000 to Palangio, claiming Palangio promised to credit those payments toward Salvatore’s purchase of the Weeden Street property in Pawtucket.
Palangio contended the payments were compensation for his acting as Salvatore’s agent in the automotive business.
Palangio gave Salvatore a partially completed handwritten "Offer to Purchase Real Estate" and Salvatore produced checks with memoranda referencing "Pawt land."
Salvatore sued (eight-count amended complaint); before verdict only promissory estoppel and unjust enrichment remained for the jury.
The jury found for Salvatore and awarded $80,815 (plus interest and costs). Palangio moved for JMOL or a new trial; the trial justice denied both.
On appeal Palangio challenged: (1) denial of his motion in limine to exclude references to his former status as a state representative; (2) denial of pretrial motions to strike Counts V–VII; and (3) the denial of JMOL/new-trial as to promissory estoppel (and unjust enrichment, which the Court did not reach).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Motion in limine to exclude references to defendant's status as state representative	References were relevant to Counts V–VII and factual context	References were prejudicial and should be barred	Court: Trial justice did not abuse discretion; limited references were permissible and were infrequent
Motions to strike Counts V–VII (criminal/public‑office allegations)	Evidence relevant; counts could be tried if supported	Counts would confuse/prejudice jury; should be struck pretrial	Court: No abuse of discretion in denying pretrial strikes; counts dismissed before deliberation and jury instructed accordingly
JMOL as to promissory estoppel (clear promise, reliance, detriment)	Evidence (conversations, handwritten purchase form, checks with memos, payments) sufficed for jury to find elements	No clear and unambiguous promise; reliance was unreasonable given co-ownership and Salvatore’s experience	Court: De novo review — viewing evidence for nonmovant, a reasonable jury could find all three elements; JMOL denied
Motion for new trial (verdict against defendant)	Verdict unsupported by evidence; trial error in admitting some evidence	Jury resolved credibility; conflicting testimony for jury to weigh	Court: Trial justice acted appropriately as "seventh juror"; did not overlook/misconstrue material evidence; new trial denied

Filippi v. Filippi, 818 A.2d 608 (R.I. 2003) (articulates three elements of promissory estoppel: clear promise, reasonable reliance, detriment)
Cote v. Aiello, 148 A.3d 537 (R.I. 2016) (discusses reasonableness of reliance in promissory‑estoppel context)
Alix v. Alix, 497 A.2d 18 (R.I. 1985) (promissory‑estoppel doctrine and relief)
East Providence Credit Union v. Geremia, 239 A.2d 725 (R.I. 1968) (promissory estoppel to avoid injustice)
Botelho v. Caster’s Inc., 970 A.2d 541 (R.I. 2009) (standard for reviewing motions for judgment as a matter of law)
Bajakian v. Erinakes, 880 A.2d 843 (R.I. 2005) (same JMOL standard and appellate review guidance)
State v. Remy, 910 A.2d 793 (R.I. 2006) (abuse‑of‑discretion standard for trial rulings)
Dellagrotta v. Dellagrotta, 873 A.2d 101 (R.I. 2005) (addressed reliance on one co‑owner’s promise where another co‑owner was silent; distinguished in this case)