Supreme Court of Rhode Island

Rhode Island Managed Eye Care, Inc. v. Blue Cross & Blue Shield of Rhode Island

June 24, 20102010 R.I. LEXIS 92

Summary

The Rhode Island Supreme Court affirmed the Superior Court’s judgment, holding that the membership data reports were admissible as business records and properly authenticated, and that the trial court did not err in granting a new trial on the lost‑profits award. The court remanded for RIMEC to accept a remittitur on the lost‑profits portion or face a new trial. The decision rests on the business‑records exception, authentication rules, and the standard of review for new‑trial motions.

Holding

  • Whether the membership data reports satisfy Rhode Island Rule 803(6) and are admissible as business records. The trial justice did not abuse discretion; the reports are admissible as business records under Rule 803(6).
  • Whether the reports were properly authenticated under Rhode Island Rule 901. The trial justice did not abuse discretion; the reports were properly authenticated under Rule 901.
  • Whether the Superior Court abused its discretion in granting a new trial on the lost‑profits award. The Superior Court’s decision was affirmed; no abuse of discretion was found.

Docket 2008-216-Appeal, 2008-217-Appeal

Cited authorities

  • Rule 803(6) of the Rhode Island Rules of Evidence
  • Rule 803(6)
  • Rule 901 of the Rhode Island Rules of Evidence
  • Rule 901(b)(1)
  • Rule 803(6)
  • Rule 803(6)
  • Rule 803(6)
  • Rule 803(6)

Cited by

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