Torrado Architects v. Rhode Island Department of Human Services
102 A.3d 655
| R.I. | 2014Background
- Torrado signed a July 1, 2008 contract to provide architectural/engineering/design services for Rhode Island Veterans Home renovations for $61,500.
- A Blanket Purchase Agreement issued April 17, 2009 referenced the July 1, 2008 contract and stated compensation was NOT TO EXCEED $61,500.
- Torrado alleged that Administrator Baccus assured additional services beyond BPA would be compensated at a higher fee tied to construction costs.
- In 2012 DHS denied Torrado’s increased fee requests via procurement forms and formal appeals, culminating in denials by the Purchasing Agent and Chief Purchasing Officer.
- The parties agreed to arbitrate while a statutory administrative appeal was pending; the arbitrator awarded only the BPA amount and expressly declined to decide equitable claims outside the arbitration scope, with judgment entered January 7, 2013.
- Torrado later petitioned to compel arbitration for equitable claims; the Superior Court denied relief on res judicata grounds, and the Rhode Island Supreme Court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the arbitration award has res judicata effect on Torrado’s petition to compel arbitration | Torrado argues equitable claims were not within the scope of the first arbitration and should not be barred by res judicata | DHS contends that the equitable claims arise from the same transaction and were or could have been raised in the first action | Yes; res judicata bars Torrado’s equitable claims arising from the same transaction |
Key Cases Cited
- Huntley v. State, 63 A.3d 526 (R.I. 2013) (restates elements of res judicata and identity of issues)
- Bossian v. Anderson, 991 A.2d 1025 (R.I. 2010) (finality of judgment and identity of issues necessary for res judicata)
- Plunkett v. State, 869 A.2d 1185 (R.I. 2005) ( Restatement-based transactional approach to determine same transaction)
- ElGabri v. Lekas, 681 A.2d 271 (R.I. 1996) (exception to res judicata for defendant’s consent to splitting claims)
- Restatement (Second) Judgments § 24, 2 Restatement (Second) of Judgments § 24 (1982) (claims extinguished include all rights of the plaintiff to remedies against defendant)
- Restatement (Second) Judgments § 26, 2 Restatement (Second) of Judgments § 26 (1982) (exceptions to splitting claims; reservations and consent to splitting)