attractive nuisance doctrine (Rhode Island) · Go Syfert
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attractive nuisance doctrine in Rhode Island

6 Rhode Island opinions name it 1 courts 1992–2022 1 in the last five years

The cases below were cited by Rhode Island courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (10)

CaseFollowedCited
Haddad v. First National Stores, Inc.green
ri · 1971 · cited in 5 Rhode Island opinions naming this issue, 1992–2013
2 sentences

2011The first case this Court considered after adopting the attractive nuisance doctrine did not apply it because the injuries in question had occurred before this Court’s decision in Haddad v. First National Stores, Inc., 109 R.I. 59 , 280 A.2d 93 (1971).

2011The first case this Court considered after adopting the attractive nuisance doctrine did not apply it because the injuries in question had occurred before this Court’s decision in Haddad v. First National Stores, Inc., 109 R.I. 59 , 280 A.2d 93 (1971).

25
Tara J. Cancel, as Administratrix of the Estate of Ira Lukens v. City of Providencegreen
ri · 2018 · cited in 1 Rhode Island opinions naming this issue, 2022–2022
1 sentence

2022Although plaintiff is correct that we have previously stated that the RUS treats users of property open to the public for recreational use as trespassers, see, e.g., Cancel v. City of Providence, 187 A.3d 347, 350 (R.I. 2018), we find no support for plaintiff’s contention that “the standard must be identical under the common law and the RUS.” However, because Berman does not aid plaintiff even if this were a RUS case, we decline to decide here whether RUS caselaw is applicable to common-law trespass cases. - 13 - Additionally, many of our previous cases on landowner liability to trespassers ha

11
Hawkins v. Town of Fostergreen
ri · 1998 · cited in 1 Rhode Island opinions naming this issue, 2013–2013
1 sentence

2013“The findings of a trial justice sitting without a jury are entitled to great weight, and the resolution of mixed questions of law and fact, as well as the inferences and conclusions drawn from the testimony and evidence, are entitled to the same deference.” Rhode Island Depositors Economic Protection Corp. v. Bowen Court Associates, 763 A.2d 1005, 1007 (R.I.2001) (quoting Hawkins v. Town of Foster, 708 A.2d 178, 182 (R.I.1998)).

11
Ferreira v. Strackgreen
ri · 1995 · cited in 1 Rhode Island opinions naming this issue, 2013–2013
1 sentence

2013We have defined “trespasser” as “[o]ne who intentionally and without consent or privilege enters another’s property.” Bennett v. Napolitano, 746 A.2d 138, 141 (R.I.2000) (quoting Ferreira v. Strack, 652 A.2d 965, 969 (R.I.1995)).

11
Bennett v. Napolitanogreen
ri · 2000 · cited in 1 Rhode Island opinions naming this issue, 2013–2013
1 sentence

2013We have defined “trespasser” as “[o]ne who intentionally and without consent or privilege enters another’s property.” Bennett v. Napolitano, 746 A.2d 138, 141 (R.I.2000) (quoting Ferreira v. Strack, 652 A.2d 965, 969 (R.I.1995)).

11
Rhode Island Depositors Economic Protection Corp. v. Bowen Court Associatesgreen
ri · 2001 · cited in 1 Rhode Island opinions naming this issue, 2013–2013
1 sentence

2013“The findings of a trial justice sitting without a jury are entitled to great weight, and the resolution of mixed questions of law and fact, as well as the inferences and conclusions drawn from the testimony and evidence, are entitled to the same deference.” Rhode Island Depositors Economic Protection Corp. v. Bowen Court Associates, 763 A.2d 1005, 1007 (R.I.2001) (quoting Hawkins v. Town of Foster, 708 A.2d 178, 182 (R.I.1998)).

11
Hill v. National Gridgreen
ri · 2011 · cited in 1 Rhode Island opinions naming this issue, 2013–2013
1 sentence

2013Ill Discussion On appeal, plaintiff argues that the trial justice erred in finding that the attractive-nuisance doctrine did not apply because plaintiff “did not fully realize the risk in taking the bottles of sulfuric acid.” The plaintiff further argues that the trial justice erred in failing to find that defendant shared “some comparative fault for the accident.” “It is a well-established principle of law that property owners owe no duty of care to trespassers but to refrain from wanton or willful conduct; and even then, *861 only upon discovering a trespasser in a position of danger.” Hill

11
Mariorenzi v. Joseph DiPonte, Inc.green
ri · 1975 · cited in 1 Rhode Island opinions naming this issue, 2011–2011
2 sentences

2011See Mariorenzi v. Joseph DiPonte, Inc., 114 R.I. 294 , 300 n. 1, 333 A.2d 127 , 130 n. 1 (1975). .

2011See Mariorenzi v. Joseph DiPonte, Inc., 114 R.I. 294 , 300 n. 1, 333 A.2d 127 , 130 n. 1 (1975). .

11
Holland v. Baltimore & Ohio Railroadgreen
dc · 1981 · cited in 1 Rhode Island opinions naming this issue, 1997–1997
2 sentences

1997Finally, because the risk of injury from an oncoming train would be apparent to anyone who decides to walk along a train trestle, we hold that as a matter of law the trestle was not an “attractive nuisance.” See Haddad, 109 R.I. at 61-67 , 280 A.2d at 95-98 (discussing and adopting the attractive-nuisance doctrine); see also Holland v. Baltimore & Ohio Railroad Co., 431 A.2d 597, 602 (D.C.Ct.App.1981) (en banc) (“[t]he overwhelming weight of authority in jurisdictions across the country is that the attractive nuisance exception does not apply as a matter of law in cases where child trespassers

1997Finally, because the risk of injury from an oncoming train would be apparent to anyone who decides to walk along a train trestle, we hold that as a matter of law the trestle was not an “attractive nuisance.” See Haddad, 109 R.I. at 61-67 , 280 A.2d at 95-98 (discussing and adopting the attractive-nuisance doctrine); see also Holland v. Baltimore & Ohio Railroad Co., 431 A.2d 597, 602 (D.C.Ct.App.1981) (en banc) (“[t]he overwhelming weight of authority in jurisdictions across the country is that the attractive nuisance exception does not apply as a matter of law in cases where child trespassers

11
Brownfield v. Missouri Pacific Railroadgreen
texapp · 1990 · cited in 1 Rhode Island opinions naming this issue, 1997–1997
2 sentences

1997Finally, because the risk of injury from an oncoming train would be apparent to anyone who decides to walk along a train trestle, we hold that as a matter of law the trestle was not an “attractive nuisance.” See Haddad, 109 R.I. at 61-67 , 280 A.2d at 95-98 (discussing and adopting the attractive-nuisance doctrine); see also Holland v. Baltimore & Ohio Railroad Co., 431 A.2d 597, 602 (D.C.Ct.App.1981) (en banc) (“[t]he overwhelming weight of authority in jurisdictions across the country is that the attractive nuisance exception does not apply as a matter of law in cases where child trespassers

1997Finally, because the risk of injury from an oncoming train would be apparent to anyone who decides to walk along a train trestle, we hold that as a matter of law the trestle was not an “attractive nuisance.” See Haddad, 109 R.I. at 61-67 , 280 A.2d at 95-98 (discussing and adopting the attractive-nuisance doctrine); see also Holland v. Baltimore & Ohio Railroad Co., 431 A.2d 597, 602 (D.C.Ct.App.1981) (en banc) (“[t]he overwhelming weight of authority in jurisdictions across the country is that the attractive nuisance exception does not apply as a matter of law in cases where child trespassers

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Rhode Island. Read the followed side critically anyway.

Also cited on this issue (3)

CaseCitedYears
Berman v. Sitrin green
ri · 2010
1 sentence

2022The attractive- nuisance doctrine, which does consider constructive discovery, has no place in the present case because it is undisputed that at the time of the accident plaintiff was eighteen years old, and “in no case have we applied the attractive-nuisance doctrine to a child older than twelve years old.” Burton, 80 A.3d at 862 . 3 We also note that Berman v. Sitrin, 991 A.2d 1038 (R.I. 2010), is a case that only considered duties owed under the RUS, not under the common law, and that the RUS is inapplicable here because the substation was decidedly not “land * * * ma[de] * * * available to

12022–2022
Steven T. Burton v. State of Rhode Island green
ri · 2013
1 sentence

2022The attractive- nuisance doctrine, which does consider constructive discovery, has no place in the present case because it is undisputed that at the time of the accident plaintiff was eighteen years old, and “in no case have we applied the attractive-nuisance doctrine to a child older than twelve years old.” Burton, 80 A.3d at 862 . 3 We also note that Berman v. Sitrin, 991 A.2d 1038 (R.I. 2010), is a case that only considered duties owed under the RUS, not under the common law, and that the RUS is inapplicable here because the substation was decidedly not “land * * * ma[de] * * * available to

12022–2022
Previte v. Wanskuck Co. green
ri · 1952
2 sentences

2000The holding in Previte v. Wanskuck Co., 80 R.I. 1, 90 A.2d 769 (1952), as it related to an infant trespasser was overruled by this Court's decision in Haddad v. First National Stores, Inc., 109 R.I. 59, 64-65 , 280 A.2d 93, 96-97 (1971), in which we adopted the attractive nuisance doctrine.

2000The holding in Previte v. Wanskuck Co., 80 R.I. 1, 90 A.2d 769 (1952), as it related to an infant trespasser was overruled by this Court's decision in Haddad v. First National Stores, Inc., 109 R.I. 59, 64-65 , 280 A.2d 93, 96-97 (1971), in which we adopted the attractive nuisance doctrine.

12000–2000

Where else courts name it

IL 48 (1921–2011) TX 39 (1931–2021) LA 33 (1949–2024) FL 33 (1925–2024) OH 32 (1968–2024) CA 31 (1919–1974) KY 24 (1918–2024) MO 20 (1939–2018) AZ 19 (1935–2024) KS 18 (1912–1995) GA 17 (1962–2010) NC 17 (1937–2012) WA 16 (1947–2020) MI 16 (1931–2018) OK 15 (1916–2024) IN 15 (1950–2012) AL 15 (1929–2009) PA 15 (1932–2013) MS 15 (1924–2005) TN 15 (1931–2002) WI 14 (1948–1998) UT 12 (1953–2024) NY 11 (1938–1964) ID 10 (1950–2007) NM 9 (1952–1998) MD 9 (1932–2019) MT 7 (1952–2010) AR 7 (1926–2017) WV 6 (1932–1992) SC 6 (1965–2011) CO 6 (1937–2013) CT 6 (1921–1993) RI 6 (1992–2022) DE 6 (1949–2022) MN 5 (1951–2001) VT 5 (1911–2026) NE 5 (1975–1992) WY 4 (1950–1995) SD 3 (1938–1980) IA 3 (1916–1969) OR 3 (1929–1977) NV 2 (1935–1972) DC 2 (1945–1981) MA 2 (1991–2006) NJ 2 (1950–1996) ME 2 (1993–1998)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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