injury-in-fact test (Rhode Island) · Go Syfert
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injury-in-fact test in Rhode Island

6 Rhode Island opinions name it 2 courts 1979–2012 0 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 (4)

CaseFollowedCited
Rhode Island Ophthalmological Society v. Cannongreen
ri · 1974 · cited in 2 Rhode Island opinions naming this issue, 1991–2009
2 sentences

2009See Bowen v. Mollis , 945 A.2d 314 , 317 (2008) ("The requisite standing to prosecute a claim for relief exists when the plaintiff has alleged that `the challenged action has caused him injury in fact, economic or otherwise[.]'") (quoting Rhode Island Ophthalmological Society v. Cannon , 113 R.I. 16 , 22 , 317 A.2d 124 , 128 (1974)).

2009See Bowen v. Mollis , 945 A.2d 314 , 317 (2008) ("The requisite standing to prosecute a claim for relief exists when the plaintiff has alleged that `the challenged action has caused him injury in fact, economic or otherwise[.]'") (quoting Rhode Island Ophthalmological Society v. Cannon , 113 R.I. 16 , 22 , 317 A.2d 124 , 128 (1974)).

12
Sennott v. Hawksleygreen
ri · 1968 · cited in 1 Rhode Island opinions naming this issue, 2012–2012
2 sentences

2012In a written decision, the motion justice ruled that it was “undisputed that plaintiffs suffered no injury beyond that suffered by the general populace and that they, therefore, cannot meet the injury-in-fact test.” Furthermore, relying on this Court’s ruling in Sennott v. Hawksley, 103 R.I. 730, 731-32 , 241 A.2d 286, 287 (1968), she found that there was no time-sensitive element that would compel the court to “leap-frog” over the issue of standing.

2012In a written decision, the motion justice ruled that it was “undisputed that plaintiffs suffered no injury beyond that suffered by the general populace and that they, therefore, cannot meet the injury-in-fact test.” Furthermore, relying on this Court’s ruling in Sennott v. Hawksley, 103 R.I. 730, 731-32 , 241 A.2d 286, 287 (1968), she found that there was no time-sensitive element that would compel the court to “leap-frog” over the issue of standing.

11
Bowen v. Mollisgreen
ri · 2008 · cited in 1 Rhode Island opinions naming this issue, 2009–2009
1 sentence

2009See Bowen v. Mollis , 945 A.2d 314 , 317 (2008) ("The requisite standing to prosecute a claim for relief exists when the plaintiff has alleged that `the challenged action has caused him injury in fact, economic or otherwise[.]'") (quoting Rhode Island Ophthalmological Society v. Cannon , 113 R.I. 16 , 22 , 317 A.2d 124 , 128 (1974)).

11
Buffi v. Ferrigreen
ri · 1969 · cited in 1 Rhode Island opinions naming this issue, 1987–1987
2 sentences

1987In noting that the injury-in-fact test has been relied upon generally to determine standing questions, we made it clear that standing could also be conferred upon an agency itself to seek review of a decision when “the public has an interest in the issue which reaches out beyond that of the immediate parties.” Id. at 393, 399 A.2d at 493 (quoting Buffi v. Ferri, 106 R.I. 349, 351 , 259 A.2d 847, 849 (1969)).

1987In noting that the injury-in-fact test has been relied upon generally to determine standing questions, we made it clear that standing could also be conferred upon an agency itself to seek review of a decision when “the public has an interest in the issue which reaches out beyond that of the immediate parties.” Id. at 393, 399 A.2d at 493 (quoting Buffi v. Ferri, 106 R.I. 349, 351 , 259 A.2d 847, 849 (1969)).

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 (4)

CaseCitedYears
Altman v. School Committee of Town of Scituate green
ri · 1975
2 sentences

1987In Altman v. School Committee of Scituate, 115 R.I. 399 , 347 A.2d 37 (1975), for example, this court held that the Scituate School Committee had standing to challenge a decision of the State Board of Regents because the public had a very real stake in the issue that was presented at the agency level.

1987In Altman v. School Committee of Scituate, 115 R.I. 399 , 347 A.2d 37 (1975), for example, this court held that the Scituate School Committee had standing to challenge a decision of the State Board of Regents because the public had a very real stake in the issue that was presented at the agency level.

21979–1987
Pontbriand v. Sundlun green
ri · 1997
1 sentence

1999Pontbriand v. Sundlun, 699 A.2d 856 (1997).

11999–1999
Matunuck Beach Hotel, Inc. v. Sheldon green
ri · 1979
1 sentence

1987In noting that the injury-in-fact test has been relied upon generally to determine standing questions, we made it clear that standing could also be conferred upon an agency itself to seek review of a decision when “the public has an interest in the issue which reaches out beyond that of the immediate parties.” Id. at 393, 399 A.2d at 493 (quoting Buffi v. Ferri, 106 R.I. 349, 351 , 259 A.2d 847, 849 (1969)).

11987–1987
Ramsay v. Sarkas green
ri · 1972
2 sentences

1979This exception, as we said in Altman v. School Committee, 115 R.I. 399 , 347 A.2d 37 (1975), “should apply when a potential challenger to an administrative action is disqualified by a literal application of the customary test and when its disqualification will inevitably result in the challenged action’s, notwithstanding its possible arbitrariness, taking on a conclusive character.” Id. at 404 , 347 A.2d at 39 . *395 Although our reasoning to this point strongly suggests that the commissioners in this case had standing under sections 15(a) and (b) of the APA to prosecute an appeal from the adm

1979This exception, as we said in Altman v. School Committee, 115 R.I. 399 , 347 A.2d 37 (1975), “should apply when a potential challenger to an administrative action is disqualified by a literal application of the customary test and when its disqualification will inevitably result in the challenged action’s, notwithstanding its possible arbitrariness, taking on a conclusive character.” Id. at 404 , 347 A.2d at 39 . *395 Although our reasoning to this point strongly suggests that the commissioners in this case had standing under sections 15(a) and (b) of the APA to prosecute an appeal from the adm

11979–1979

Statutes the citing opinions construe

RI § R.I. Gen. Laws § 42-35-15 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CO 39 (1984–2026) NY 29 (1984–2025) WA 26 (1985–2026) HI 15 (1996–2025) TX 14 (2003–2025) FL 10 (1985–2023) CA 9 (1996–2023) NM 9 (2008–2023) DC 7 (1980–2021) NC 6 (2021–2022) RI 6 (1979–2012) MN 4 (1993–2016) KY 4 (2005–2020) ID 4 (1996–2023) AK 3 (1976–1982) OH 3 (2017–2022) MI 3 (2007–2010) GA 3 (2022–2025) NE 3 (2019–2025) MO 3 (2017–2024) VT 3 (2007–2024) PA 3 (2022–2023) IL 2 (2015–2019) IA 2 (2020–2025) WV 2 (2004–2021) UT 2 (2004–2018) VA 2 (2016–2016) ND 2 (1995–2008) CT 2 (1978–1992) KS 2 (2013–2022) MD 2 (2011–2013) TN 2 (2022–2025)

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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