Supreme Court of Rhode Island

Andrea Lynch v. Jason Gardner and Timothy Gardner as Joint Executors of the Estate of James Gardner

March 23, 2026

Summary

The Supreme Court affirmed the Superior Court’s summary‑judgment ruling, holding that the original complaint filed against a deceased party was a legal nullity, that Rule 15(c) could not relate the amendment back, and that the claim was barred by the one‑year limitations period of G.L. 1956 § 9‑1‑21. The Court also reiterated that summary‑judgment decisions are reviewed de novo.