Latonya Marzett v. Amanda Letendre, alias

Syllabus

The instant case involves a dispute between the plaintiff-landlord, Latonya Marzett, and the defendants-tenants, Amanda Letendre and Jason Gamache, with respect to conduct that allegedly occurred in the context of their landlord-tenant relationship. The issue in the case was the narrow and potentially dispositive issue of whether or not the Superior Court—where the complaint in this case was originally filed—had subject matter jurisdiction with respect to this case. The hearing justice found that the Superior Court could not properly exercise subject matter jurisdiction in this matter. Accordingly, she dismissed the plaintiff's complaint as well as the defendants' counterclaims, and the plaintiff timely appealed. After carefully perusing two relevant provisions of the General Laws—G.L. 1956 §§ 8-8-3(a)(2) and 34-18-9—the Supreme Court held that the hearing justice acted properly in dismissing the case for lack of subject matter jurisdiction, because the actions alleged in the complaint arose out of the landlord-tenant relationship, and therefore the case should have been originally filed in the District Court.