Saint Elizabeth Home v. Rebecca Gorham, 266 A.3d 112

Saint Elizabeth Home (a skilled nursing facility) admitted Mary Moore on March 16, 2018; three days later Moore’s daughter and representative, Rebecca Gorham, signed an admission agreement personally guaranteeing payment for Moore’s care.
The agreement required Gorham to apply promptly for Medicare/other benefits and to notify Saint Elizabeth in writing if Moore’s economic status changed, but expressly stated Moore and Gorham remained liable for the entire amount due.
Saint Elizabeth sued Gorham on August 2, 2019 for unpaid charges; by then roughly $92,309 had accrued, Medicaid later paid over half, leaving $44,563 outstanding.
Saint Elizabeth moved for summary judgment arguing Gorham had contractually assumed personal liability; Gorham countered that the facility failed to assist or timely advise about Medicaid applications, causing the deficiency.
The Superior Court granted summary judgment for Saint Elizabeth for $44,563, finding the contract unambiguous and that Gorham admitted the duty to apply for Medicaid; the Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Gorham is personally liable for unpaid charges under the admission agreement	Saint Elizabeth: Agreement unambiguously makes Gorham personally liable for all amounts due	Gorham: Facility’s failure to assist or advise on Medicaid caused the unpaid balance	Held: Gorham is personally liable; agreement is clear and binding
Whether the admission agreement obligated Saint Elizabeth to assist with Medicaid application	Saint Elizabeth: No such obligation in the contract	Gorham: Facility had a duty to act/assist in Medicaid process and should have prompted earlier application	Held: Agreement imposes no duty on facility to assist; Gorham was required to apply and notify
Whether factual disputes (good faith/mitigation) precluded summary judgment	Saint Elizabeth: No genuine factual dispute; entitled to judgment as a matter of law	Gorham: Alleged failure to mitigate and bad faith by plaintiff created triable issues	Held: Gorham failed to produce competent evidence of disputed material facts; summary judgment proper

Middle Creek Farm, LLC v. Portsmouth Water & Fire District, 252 A.3d 745 (R.I. 2021) (standard of de novo review on appeal from summary judgment)
Boudreau v. Automatic Temperature Controls, Inc., 212 A.3d 594 (R.I. 2019) (view evidence in light most favorable to nonmoving party on summary judgment)
Citizens Bank, N.A. v. Palermo, 247 A.3d 131 (R.I. 2021) (nonmoving party must produce competent evidence to avoid summary judgment)
Hexagon Holdings, Inc. v. Carlisle Syntec Incorporated, 199 A.3d 1034 (R.I. 2019) (clear contract language controls parties’ intent)
Cathay Cathay, Inc. v. Vindalu, LLC, 962 A.2d 740 (R.I. 2009) (contract interpretation principles)
Nelson v. Allstate Insurance Company, 228 A.3d 983 (R.I. 2020) (burden on nonmoving party to prove disputed material facts with competent evidence)
JHRW, LLC v. Seaport Studios, Inc., 212 A.3d 168 (R.I. 2019) (nonmovant cannot rely on mere allegations or conclusions to defeat summary judgment)