City of Pawtucket v. The Rhode Island Department of Revenue

Syllabus

The plaintiff, the City of Pawtucket (the City), petitioned the Supreme Court for the issuance of a writ of certiorari to review a July 27, 2021 judgment granted in favor of the defendants—the Rhode Island Department of Revenue (DOR) and other named individuals in their official capacities. The Supreme Court granted the City's petition on April 15, 2022. The City argued before the Court that the hearing justice erred in upholding the DOR's interpretation of G.L. 1956 § 45 13-5.1 (the PILOT Act) to the effect that the properties at issue were not eligible for PILOT funds.<br><br>Before turning to the merits, the Court first addressed the defendants' contention that the City's appeal was untimely. The Court held that, pursuant to either G.L. 1956 § 45-13-5.2 or G.L. 1956 § 42-35-15(b), the City's appeal was in fact timely. <br><br>The Court next held that the two properties owned by The Memorial Hospital did not satisfy the definition of \nonprofit hospital facility\ as defined in § 45-13-5.1(c) and that, for that reason, the City was not eligible to receive PILOT funds pursuant to § 45-13-5.1 for fiscal year 2021 and fiscal year 2022.<br><br>Accordingly, the Court affirmed the judgment of the Superior Court. <br><br>