Narrative Opinion Summary
The case involves an appeal by Richard J. Connelly concerning the denial of prejudgment interest on accidental disability benefits awarded through a writ of certiorari. The primary legal question was whether the statutory provision for interest in civil actions, specifically G.L. 1956 § 9-21-10, was applicable in this context. In the underlying case, the court had directed the City of Providence Retirement Board to grant benefits to the appellant, but the Superior Court's subsequent enforcement via writ of mandamus did not constitute a judgment awarding damages. The court clarified that 'judgment' under the statute pertains to a final decision after considering objections. It ruled that the writ of certiorari already represented the final judgment. As such, the determination of benefits was not an award of damages meriting prejudgment interest. The appeal was denied and dismissed, with the case remanded to the Superior Court. Chief Justice Fay abstained from participation in the decision.
Legal Issues Addressed
Application of Prejudgment Interest under Civil Actionssubscribe to see similar legal issues
Application: The court determined that prejudgment interest pursuant to G.L. 1956 § 9-21-10 does not apply to the issuance of a writ of certiorari directing the award of benefits as it does not constitute a final judgment awarding damages.
Reasoning: The court concluded that the writ of certiorari issued by this court constituted the necessary final judgment.
Definition of 'Judgment' under § 9-21-10subscribe to see similar legal issues
Application: The term 'judgment' within the statute refers to a final decision affirmed by the court after considering and rejecting objections, which was not applicable in this case as the determination of benefits was not recognized as an award of damages.
Reasoning: The court clarified that the term 'judgment' in § 9-21-10 refers to a final judgment affirmed by the court after evaluating and rejecting objections, as established in prior cases.
Role of Writ of Mandamus in Enforcing Court Orderssubscribe to see similar legal issues
Application: This case affirmed that a writ of mandamus from the Superior Court serves to enforce prior court orders and does not independently constitute a basis for awarding prejudgment interest.
Reasoning: The subsequent writ of mandamus from the Superior Court simply enforced the prior order, and the determination of benefits did not qualify as an award of damages under the statute.