Manuel Andrews, Jr. v. James J. Lombardi

Summary

The Rhode Island Supreme Court affirmed the Superior Court’s denial of prejudgment interest on past‑due COLA payments, holding that the awards stemmed from constitutional claims, not contract or tort claims, and therefore the statutory prejudgment interest provision does not apply. The Court emphasized that the statute is strictly construed to cover only tort and contract actions and declined to extend it to constitutional doctrines.