R.I. Gen. Laws
Rhode Island General Laws

R.I. Gen. Laws § 10-3-14 (2026)

Modification or correction of award

✓ current as of July 2026
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(a) In any of the following cases, the court must make an order modifying or correcting the award, upon the application of any party to the arbitration:

(1) Where there was an evident material miscalculation of figures, or an evident material mistake in the description of any person, thing, or property referred to in the award.

(2) Where the arbitrators have awarded upon a matter not submitted to them, unless it is a matter not affecting the merits of the decision upon the matters submitted.

(3) Where the award is imperfect in matter of form not affecting the merits of the controversy.

(b) The order must modify and correct the award, so as to effect the intent thereof and promote justice between the parties.

Notes of Decisions
Cited in 16 cases (2 in the last 5 years), 1978–2025 · leading case: Pier House Inn, Inc. v. 421 Corp., Inc., 812 A.2d 799 (R.I. 2002).
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Pier House Inn, Inc. v. 421 Corp., Inc., 812 A.2d 799 (R.I. 2002). · cites it 44× “It is our opinion that this blatant discrepancy clearly exemplifies the type of award that § 10-3-14 authorizes a judge to modify or correct, in the interest of effectuating the intent of the award and promoting justice between the parties.”
Joyce Wheeler v. Encompass Ins. Co., 66 A.3d 477 (R.I. 2013). · cites it 28× “However, this difference is immaterial to our analysis because chapter 9 of title 28 and chapter 3 of title 10 employ virtually identical language to define the contours of a trial justice‘s authority to confirm, modify, or vacate an arbitration award.”
Joseph Lemerise v. The Com. Ins. Co., 137 A.3d 696 (R.I. 2016). · cites it 14× “The defendant promptly objected to plaintiff’s motion to confirm and filed its own motion, pursuant to § 10-3-14, to modify/correct the arbitration award to conform with the insurance policy, which provided uninsured-motorist coverage up to a limit of $100,000.”
Pierce v. Rhode Island Hosp., 875 A.2d 424 (R.I. 2005). · cites it 3× “Given the “conspicuous incongruity” between the initial amount of interest awarded and the proper amount as prescribed by § 9-21-10(b), which was facially apparent in the award, the arbitrator was justified in correcting this “evident material miscalculation” under § 10-3-14 to…”
Paola v. Com. Union Assurance Companies, 461 A.2d 935 (R.I. 1983). · cites it 2× “A trial justice has no power to modify an award unless there has been miscalculation of figures, or mistake in description of property or person; or where the award is imperfect in form only; or where the arbitrator made an award concerning a matter not before them unless such…”
Dutson v. Nationwide Mut. Ins., 383 A.2d 597 (R.I. 1978). · cites it 2× “” Section 10-3-14. An award may be vacated where it was procured by corruption or fraud, where there was evident partiality, corruption or misconduct on the part of the arbitrators, or where the arbitrators exceeded their powers or so imperfectly executed them that a mutual,…”
Drago Custom Interiors, LLC v. Carlisle Bldg. Sys., Inc., 57 A.3d 668 (R.I. 2012). · cites it 4× “This Court explained that the “blatant discrepancy” in the award — awarding punitive damages to the lessee while, at the same time, finding that the lessee breached the lease, compounded by an award of attorneys’ fees to the lessor— “clearly exemplifies the type of award that §…”
Balian v. Allstate Ins. Co., 610 A.2d 546 (R.I. 1992). · cites it 2× “Section 10-3-14. 6 . Section 27-7-2.1(0) provides that "[w]henever an insured has paid two (2) or more separate premiums for uninsured motorists’ coverage in a single policy of insurance or under several policies with the same insurance company, the insured shall be permitted to…”
Metro. Prop. & Cas. Ins. v. Tanasio, 703 A.2d 1102 (R.I. 1997). · cites it 2× “Accordingly, since the trial justice, pursuant to G.L. 1956 § 10-3-14, had clear authority to supplement the arbitrator’s incomplete award, we conclude that his decision was without error.”
Atwood Health Props., LLC v. Calson Constr. Co. v. Gem Plumbing & Heating Co., Inc., 111 A.3d 311 (R.I. 2015). “” Additionally, § 10-3-14 directs the courts to modify or correct an award under the following limited circumstances: “(a) * * * “(1) Where there was an evident material miscalculation of figures, or an evident material mistake in the description of any person, thing, or…”
Wayne Distrib. Co. v. Piti Bldg. Co., Inc., 512 A.2d 870 (R.I. 1986). “1956 (1985 Reenactment) §§ 10-3-14(a)(1), 10-3-14(a)(3), and 10-3-12(4), respectively.”
Fort Hill Builders, Inc. v. Nat'l Grange Mut. Ins., 682 F. Supp. 145 (D.R.I. 1988). · cites it 2× “Section 10-3-14. To allow a Superior Court justice to add interest to a proper award would be to grant a much broader authority than the Legis *148 lature intended.”
Show all 16 citing cases →
— R.I. Gen. Laws § 10-3-14(a) — 4 cases
Joyce Wheeler v. Encompass Ins. Co., 66 A.3d 477 (R.I. 2013). “However, this difference is immaterial to our analysis because chapter 9 of title 28 and chapter 3 of title 10 employ virtually identical language to define the contours of a trial justice‘s authority to confirm, modify, or vacate an arbitration award.”
Pier House Inn, Inc. v. 421 Corp., Inc., 812 A.2d 799 (R.I. 2002). “It is our opinion that this blatant discrepancy clearly exemplifies the type of award that § 10-3-14 authorizes a judge to modify or correct, in the interest of effectuating the intent of the award and promoting justice between the parties.”
Pierce v. Rhode Island Hosp., 875 A.2d 424 (R.I. 2005). “Given the “conspicuous incongruity” between the initial amount of interest awarded and the proper amount as prescribed by § 9-21-10(b), which was facially apparent in the award, the arbitrator was justified in correcting this “evident material miscalculation” under § 10-3-14 to…”
Mullowney v. USAA Cas. Ins. Co. (D.R.I. 2023).
— R.I. Gen. Laws § 10-3-14(a)(1) — 1 case
Wayne Distrib. Co. v. Piti Bldg. Co., Inc., 512 A.2d 870 (R.I. 1986). “1956 (1985 Reenactment) §§ 10-3-14(a)(1), 10-3-14(a)(3), and 10-3-12(4), respectively.”
— R.I. Gen. Laws § 10-3-14(a)(2) — 1 case
Joyce Wheeler v. Encompass Ins. Co., 66 A.3d 477 (R.I. 2013). “However, this difference is immaterial to our analysis because chapter 9 of title 28 and chapter 3 of title 10 employ virtually identical language to define the contours of a trial justice‘s authority to confirm, modify, or vacate an arbitration award.”
— R.I. Gen. Laws § 10-3-14(b) — 2 cases
Pier House Inn, Inc. v. 421 Corp., Inc., 812 A.2d 799 (R.I. 2002). “It is our opinion that this blatant discrepancy clearly exemplifies the type of award that § 10-3-14 authorizes a judge to modify or correct, in the interest of effectuating the intent of the award and promoting justice between the parties.”
Joyce Wheeler v. Encompass Ins. Co., 66 A.3d 477 (R.I. 2013). “However, this difference is immaterial to our analysis because chapter 9 of title 28 and chapter 3 of title 10 employ virtually identical language to define the contours of a trial justice‘s authority to confirm, modify, or vacate an arbitration award.”
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