Supreme Court of Rhode Island

Carol Allen v. Laura Sitrin, as Finance Director for the City of Newport

May 23, 2024

Summary

The Supreme Court of Rhode Island vacated the Superior Court judgments that had awarded damages to the plaintiff and remanded for entry of judgment in favor of the city defendants. The Court held that the Connecticut Rule applies based on whether the plaintiff’s injury was caused by an accumulation of snow or ice, not on the amount of accumulation, and that the unusual‑circumstances exception did not apply because the defendants took no affirmative actions that increased the risk. Accordingly, the city defendants owed no duty until a reasonable time after the storm ended.