Kevin M. Blais v. Rhode Island Airport Corporation

Syllabus

The Rhode Island Airport Corporation (RIAC) sought review of a judgment in favor of the plaintiff, Kevin Blais, that reversed RIAC's decision to prohibit Blais from entering North Central State Airport. Before the Supreme Court on writ of certiorari, RIAC argued that it had the authority to ban an individual from any one of its airports without issuing a formal order. In the alternative, it argued that its communications to Blais complied with all statutory requirements of the Uniform Aeronautical Regulatory Act. RIAC also asserted that Blais's administrative appeal was time barred. The Supreme Court held that, although Blais had subsequently been allowed back onto North Central State Airport, this case was not moot because Blais had alleged in related litigation that RIAC continued to review Blais's status. The Court concluded that RIAC did not have authority to permanently prohibit entry onto its airports without issuing a formal order, and it described the procedural requirements that such an order must meet to be enforced. The Court concluded that RIAC had not complied with those requirements and that Blais's administrative appeal was timely. Accordingly, the Court affirmed the judgment of the Superior Court.