John Devaney v. St. Thomas More Catholic Church

Summary

The Supreme Court of Rhode Island affirmed the Superior Court’s dismissal of the plaintiff’s nuisance suit, finding that the trial justice did not abuse discretion in imposing a Rule 37(b) sanction for the plaintiff’s repeated failure to provide complete expert‑witness disclosures. The Court held that pro se status does not excuse noncompliance and that speculative expert answers violate Rule 26(b)(4)(A).