PROVIDENCE, R.I. (Legal Newsline) – The Rhode Island Supreme Court has affirmed a lower court’s decision stipulating that no basis exists for holding a defendant individually liable in a case where the plaintiffs had already accrued $395,000 from other defendants.
The court interpreted the state's Wrongful Death Act on March 27 in a way that prevents plaintiffs from recovering from multiple defendants for a single fatal incident.
"Whether the decedent’s death was caused by one tortfeasor or multiple tortfeasors, the act’s remedial goal—and the amount of loss endured by the estate— remains the same," the court ruled.
"The plaintiffs’ proposed statutory interpretation could yield absurd results in that the estate’s loss in a wrongful-death case could depend on the number of defendants.
"That a decedent’s death was caused by ten defendants rather than one would produce ten times more damages despite the estate enduring an identical loss. Such a result surely was not intended by the General Assembly."
Jason Goffe and Michael Petrarca were high-speed racing near Coventry in March 2003 when Goffe lost control of his vehicle and careened into an eastbound lane, where William Walmsley struck Goffe’s vehicle, instantly killing him and his passenger, Brendan O’Connell Roberti.
Roberti’s parents, Maureen O’Connell and Paul Roberti, filed suit against several defendants in 2005, with Walmsley being among the individuals fingered as responsible for their son’s death. Also named as defendants were Goffe, his father, who owned the car he was driving at the time of the accident, and GEICO, his insurer at the time of the deadly crash.
By the time the cases were slated to go to trial, all but Walmsley had entered into a settlement arrangement totaling the $395,000 paid out to Roberti’s estate.
At trial, a jury found Walmsley negligent in 2010 and concluded that his negligence was a direct cause of Roberti’s death, prompting Roberti’s parents to ultimately seek an additional $250,000 in damages.
Though Walmsley’s blood alcohol level was found to be at 0.106, a level an expert witness testified could “significantly impair,” perception and reaction time, the Supreme Court ruled that the Wrongful Death Act is subject to joint and several liability principles.
In all, Walmsley’s fault in the accident was found to be at 3 percent. He was never criminally charged in the case.