Rhode Island Joint Reinsurance Association v. Brenda Ricci (Rhode Island 2026)

Summary

The Supreme Court of Rhode Island affirmed the Superior Court judgment and the trial justice’s denial of the defendants’ motions for a new trial, holding that the trial justice did not abuse discretion in her evidentiary rulings, refusal to order appraisal, jury instruction decisions, and that the defendants waived objections to the jury instructions. The Court also affirmed that the implied‑covenant claim was waived.

Holding

Did the trial justice abuse discretion in denying the Riccis’ motions in limine to preclude RIJRA’s fraud evidence?. The trial justice did not abuse her discretion; the denial of the motions in limine is affirmed.

Did the trial justice err in refusing to order appraisal of the loss under the insurance policy?. The trial justice’s refusal to order appraisal is affirmed; no abuse of discretion was found.

Did the trial justice err in admitting the deposition testimony of Mr. Christian regarding fraud?. The admission of the deposition is affirmed; the trial justice did not abuse discretion.

Did the trial justice err in excluding the text‑message evidence and the eviction‑proceeding transcript?. The exclusions are affirmed; the trial justice did not err in exercising discretion over admissibility.

Did the trial justice err in the jury instructions, including the failure to define “vandalism” and to include a theft instruction?. The jury‑instruction rulings are affirmed; the Riccis waived objections to the instructions.

Did the trial justice err in denying the Riccis’ motions for a new trial and the implied‑covenant claim?. The denial of the new‑trial motions is affirmed; the implied‑covenant claim was waived and the trial justice’s analysis satisfied the abuse‑of‑discretion standard.

Summary

Holding

Cited authorities