Webster Bank, National Association v. Arnold S. Rosenbaum

Syllabus

The defendants, Arnold S. Rosenbaum and Judith A. Rosenbaum, appealed from of a Superior Court judgment in favor of the plaintiff, Webster Bank, National Association, following the trial justice's decision on the parties' cross-motions for summary judgment. The defendants contended that the trial justice erred in applying the Rhode Island ten-year statute of limitations pursuant to G.L. 1956 § 9-1-13, rather than the Connecticut six-year statute of limitations under Connecticut General Statutes § 52-576, which would have barred plaintiff's civil action against them for breach of a loan agreement. The defendants based their argument upon a governing-law provision in the loan agreement. The Supreme Court concluded that, because the loan agreement did not clearly specify either the choice of forum or the statute of limitations that would apply to an action arising from a breach of the loan agreement, the Court was bound to apply its interest-weighing approach to determine which state's statute of limitations would apply. The Supreme Court held that the trial justice did not err in finding that the Rhode Island statute of limitations applied under the interest-weighing test and that plaintiff's claim was thus not barred. Accordingly, the Supreme Court affirmed the judgment of the Superior Court.