The Providence Community Health Centers, Inc. v. Neal Dupuis, in his capacity as Tax Assessor for the City of Warwick

Syllabus

The plaintiff, The Providence Community Health Centers, Inc. (PCHC or plaintiff), appealed from a Superior Court judgment entered in favor of the defendant, Neal Dupuis, in his capacity as Tax Assessor for the City of Warwick (the tax assessor or defendant), following the grant of the defendant's motion for summary judgment. At issue was whether G.L. 1956 § 44-3-3(a)(70) granted the plaintiff a specific exemption for its property, or if § 44-3-3(a)(12) provided the plaintiff with a general exemption. The Supreme Court concluded that the plain language of § 44-3-3(a)(70) unambiguously granted PCHC a tax exemption limited to its real property located in Providence; it also concluded that § 44-3-3(a)(12) was ambiguous, as applied to the facts of this case, and must be resolved in favor of the taxing authority. The judgment of the Superior Court was therefore affirmed.