Michael J. Salvatore v. Thomas A. Palangio

Syllabus

This case involved a dispute between the plaintiff (Michael Salvatore) and the defendant (Thomas Palangio) concerning the purchase and sale of certain real property in Pawtucket, Rhode Island. The dispute between the parties eventually resulted in litigation in the Providence County Superior Court and, finally, in a jury trial in November of 2017. The jury, which deliberated on the claims sounding in promissory estoppel and unjust enrichment, returned a verdict in favor of Mr. Salvatore. Mr. Palangio filed a renewed motion for judgment as a matter of law or, in the alternative, a motion for a new trial. The trial justice denied both motions, and Mr. Palangio appealed to the Supreme Court, contending that the trial justice erred in denying those motions. Mr. Palangio also argued on appeal that, by denying his motion in limine and by failing to strike certain counts in the amended complaint before trial, the trial justice abused his discretion. The Supreme Court held that there was sufficient evidence for a reasonable jury to find that Mr. Salvatore had proved his claim for promissory estoppel. In light of its conclusion as to the claim for promissory estoppel, the Court did not reach the issue of unjust enrichment. The Supreme Court further held that the trial justice did not abuse his discretion with respect to the motion in limine or the motions to strike. Accordingly, the Court affirmed the judgment of the Superior Court.