You are viewing a free summary from Descrybe.ai. For citation checking, legal issue analysis, and other advanced tools, explore our Legal Research Toolkit — not free, but close.

Dexter Credit Union v. City of Central Falls

Citations: 634 A.2d 1174; 1993 R.I. LEXIS 274; 1993 WL 536840Docket: No. 93-116-Appeal

Court: Supreme Court of Rhode Island; December 15, 1993; Rhode Island; State Supreme Court

Narrative Opinion Summary

In this case, the court addressed an appeal concerning a preliminary injunction issued by the Superior Court, which barred the defendants from obstructing the plaintiff's access to Dexter Street, a recognized state highway. The central legal question was whether the hearing justice abused his discretion in granting this injunction. The plaintiff, a credit union, argued that the obstruction of its curb cut caused irreparable harm and violated a permit issued by the Rhode Island Department of Transportation, which had sanctioned the relocation and closure of curb cuts while ensuring safe access to the premises. The hearing justice found that the city's barricade indeed caused irreparable harm and that the plaintiff showed a high likelihood of success on the merits. The appellate court, upon reviewing the arguments and evidence presented by both parties, found no abuse of discretion by the lower court. Consequently, the appeal was denied, and the injunction requiring the removal of obstructions and restoration of access was upheld. This decision affirmed the plaintiff's right to unobstructed access as granted by the DOT permit, emphasizing the legal standards for preliminary injunctions and the discretion afforded to trial courts in such matters.

Legal Issues Addressed

Denial of Appeal for Abuse of Discretion

Application: The appellate court upheld the preliminary injunction, finding no abuse of discretion by the hearing justice after reviewing the submissions from both parties.

Reasoning: The court found no evidence of abuse of discretion by the hearing justice after considering the arguments and submissions from both parties. Consequently, the defendants' appeal was denied and dismissed, and the original judgment was affirmed.

Irreparable Harm and Likelihood of Success

Application: The hearing justice concluded that the obstruction caused irreparable harm and that the plaintiff demonstrated a high likelihood of success on the merits, justifying the preliminary injunction.

Reasoning: The hearing justice also determined that a barricade erected by the city of Central Falls obstructed one of the plaintiff's curb cuts, causing irreparable harm, and noted that the plaintiff demonstrated a high likelihood of success on the merits of the case.

Preliminary Injunction Standards

Application: The court assessed whether the hearing justice abused discretion in issuing a preliminary injunction that prevented obstruction of access and required restoration of a curb cut.

Reasoning: The review focused on whether the hearing justice had abused his discretion in granting the preliminary injunction.

State Highway Jurisdiction

Application: The court confirmed that Dexter Street falls under the jurisdiction of the Rhode Island Department of Transportation and that the DOT's permit implied safe access for the plaintiff.

Reasoning: Key findings by the hearing justice included: Dexter Street being a state highway under the jurisdiction of the Rhode Island Department of Transportation (DOT), the DOT having issued a Physical Alteration Permit allowing relocation and closure of curb cuts, and that the permit implicitly ensured safe access to the plaintiff's premises.