Maureen O'Connell v. William Walmsley

Citations

• 156 A.3d 422
• 2017 WL 1154712
• 2017 R.I. LEXIS 38

Syllabus

This appeal stemmed from a tragic automobile accident that occurred on the evening of March 9, 2003, in Coventry, Rhode Island, the details of which are outlined at length in a predecessor case: O'Connell v. Walmsley, 93 A.3d 60 (R.I. 2014). The defendant, William Walmsley, a driver deemed 3 percent at fault for the accident, sought summary judgment, asserting that the statutory minimum damages amount was previously satisfied by settlement agreements with other defendants. The plaintiffs argued that, despite the prior settlements that exceeded $250,000, G.L. 1956 § 10-7-2—the statutory minimum corresponding with wrongful-death cases—mandated that the defendant was individually liable for $250,000. On appeal, the Supreme Court rejected the plaintiffs' rigid and technical plain-language reading of § 10-7-2 because it would yield an absurd result. Instead, the Court sought to effectuate the underlying compensatory purpose of the Wrongful Death Act. To this end, and reviewing the entire statutory scheme in light of common sense, the Court concluded that the legislature intended the minimum-damages provision to apply on a per-claim—rather than per-defendant—basis. Thus, the Court affirmed the judgment of the Superior Court.