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.

Blais v. Beacon Mutual Insurance

Citations: 812 A.2d 838; 2002 R.I. LEXIS 220; 2002 WL 31899253Docket: No. 2001-226-Appeal

Court: Supreme Court of Rhode Island; December 1, 2002; Rhode Island; State Supreme Court

Narrative Opinion Summary

This case involves an appeal by an individual against The Beacon Mutual Insurance Company concerning a request for information under the Access to Public Records Act. The appellant sought declaratory and injunctive relief, claiming entitlement to certain vendor information from Beacon. However, the trial justice ruled that Beacon, as a non-profit public corporation, is not a state agency as defined by the statute and therefore not obligated under the Act. The Supreme Court addressed the procedural aspect of the appeal, noting that it was filed 22 days after the judgment, thus exceeding the mandatory 20-day appeal period outlined in Supreme Court rules. Consequently, the appeal was dismissed as untimely. The Court also affirmed that the trial justice's ruling would stand on its merits, citing an 'Agreed Statement of Facts'. The dismissal of the appeal and affirmation of the trial court's decision underscore the strict adherence to procedural timelines and statutory definitions in determining the applicability of public records laws.

Legal Issues Addressed

Access to Public Records Act Applicability

Application: Beacon Mutual Insurance Company is not subject to the Access to Public Records Act as it is not classified as a state agency.

Reasoning: The trial justice determined that Beacon, established as a non-profit public corporation under a legislative charter, is not classified as a state agency and is not subject to the Act.

Effective Date of Judgments

Application: Judgments are effective upon being signed and entered by the clerk, impacting the calculation of appeal deadlines.

Reasoning: The court emphasized that the appeal period is mandatory and that judgments are effective upon being signed and entered by the clerk.

Timeliness of Appeals

Application: The appellant's failure to file within the 20-day period results in the dismissal of the appeal as untimely.

Reasoning: Blais's appeal was deemed untimely as he filed it 22 days after the first valid judgment was entered on May 14, 2001, exceeding the 20-day appeal period in Supreme Court rules.