Rhode Island General Laws

R.I. Gen. Laws § 9-1-14.3 (2026)

Limitation on legal malpractice actions

✓ current as of July 2026
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Notwithstanding the provisions of §§ 9-1-13 and 9-1-14, an action for legal malpractice shall be commenced within three (3) years of the occurrence of the incident which gave rise to the action; provided, however, that:

(1) One who is under disability by reason of age, mental incompetence, or otherwise, and on whose behalf no action is brought within the period of three (3) years from the time of the occurrence of the incident, shall bring the action within three (3) years from the removal of the disability.

(2) In respect to those injuries due to acts of legal malpractice which could not in the exercise of reasonable diligence be discoverable at the time of the occurrence of the incident which gave rise to the action, suit shall be commenced within three (3) years of the time that the act or acts of legal malpractice should, in the exercise of reasonable diligence, have been discovered.

Notes of Decisions
Cited in 18 cases (1 in the last 5 years), 1994–2026 · leading case: Charles E. Fogarty v. Ralph Palumbo James Ottenbacher v. Ralph Palumbo, 163 A.3d 526 (R.I. 2017).
Charles E. Fogarty v. Ralph Palumbo James Ottenbacher v. Ralph Palumbo, 163 A.3d 526 (R.I. 2017). · cites it 11× “” Unable to satisfy the requirements of the discovery-rule exception to the three-year statute of limitations set forth in G.L. 1956 § 9-1-14.3 10 for legal malpractice claims, plaintiffs’ 2010 claims against Pilgrim were deemed untimely.”
Sharkey v. Prescott, 19 A.3d 62 (R.I. 2011). · cites it 20× “The defendant argued that the action was brought outside of the applicable statute of limitations for legal-malpractice claims codified at G.L.1956 § 9-1-14.3 because plaintiff's action was commenced more than three years since the incidents giving rise to it occurred.”
Mendes v. Factor, 41 A.3d 994 (R.I. 2012). · cites it 8× “1956 § 9-l-13(a), 13 and that their negligence claims were barred by the three-year limitation for legal malpractice, as set forth in § 9-1-14.3. 14 On appeal, plaintiffs attempt to forestall the death knell for their claims by raising two related theories: the continuous course…”
Canavan v. Lovett, Schefrin & Harnett, 862 A.2d 778 (R.I. 2004). · cites it 6× “1 The Superior Court granted summary judgment in favor of the defendants, reasoning that the plaintiffs cause of action was barred by the applicable statute of limitations for legal malpractice actions as prescribed by G.L.1956 § 9-1-14.3. On appeal, the plaintiff contends that…”
Zanni v. Voccola, 13 A.3d 1068 (R.I. 2011). · cites it 5× “3(2), which says: “In respect to those injuries due to acts of legal malpractice which could not in the exercise of reasonable diligence be discoverable at the time of the occurrence of the incident which gave rise to the action, suit shall be commenced within three (3) years of…”
Harvey v. Snow, 281 F. Supp. 2d 376 (D.R.I. 2003). · cites it 10× “R.I. Gen. Laws § 9-1-14.3. Section 9-1-14.”
Ciambrone v. Coia & Lepore, Ltd., 819 A.2d 207 (R.I. 2003). · cites it 6× “A Superior Court hearing justice granted summary judgment in defendants’ favor on the ground that the suit was time-barred pursuant to G.L.1956 § 9-1-14.3. 1 The plaintiff timely appealed.”
Artecia Behroozi v. Allen Kirshenbaum, 128 A.3d 869 (R.I. 2016). · cites it 2× “Statute of Limitations General Laws 1956 § 9-1-14.3 sets forth a three-year statute of limitations for legal malpractice claims.”
Penn-Dutch Kitchens, Inc. v. Grady, 651 A.2d 731 (R.I. 1994). · cites it 7× “1956 (1985 Reenactment) § 9-1-14.3, as enacted by P.L.1988, ch. 212, § 1.”
Rocchio v. Moretti, 694 A.2d 704 (R.I. 1997). · cites it 5× “Moretti and Perlow filed a motion for summary judgment on January 31,1995, alleging that the plaintiffs’ action was barred by the three-year statute of limitations for legal malpractice actions found in G.L.1956 § 9-1-14.3, as enacted by P.L.1988, eh.”
Guay v. Dolan, 685 A.2d 269 (R.I. 1996). · cites it 5× “Dolan moved to dismiss the complaint on the ground that the three-year statute of limitations, as codified in G.L.1956 § 9-1-14.3, had expired. At a hearing on March 28, 1995, a Superior Court justice granted Dolan’s motion.”
Henry v. Sheffield, 856 F. Supp. 2d 345 (D.R.I. 2012). · cites it 2× “R.I. Gen. Laws § 9-1-14.3(2). It is undisputed that Plaintiff Corinna learned in the fall of 2004 that a change was made to Captain Henry’s will (or to the codicil) that affected her interests.”
— R.I. Gen. Laws § 9-1-14.3(2) — 9 cases
Charles E. Fogarty v. Ralph Palumbo James Ottenbacher v. Ralph Palumbo, 163 A.3d 526 (R.I. 2017). “” Unable to satisfy the requirements of the discovery-rule exception to the three-year statute of limitations set forth in G.L. 1956 § 9-1-14.3 10 for legal malpractice claims, plaintiffs’ 2010 claims against Pilgrim were deemed untimely.”
Sharkey v. Prescott, 19 A.3d 62 (R.I. 2011). “The defendant argued that the action was brought outside of the applicable statute of limitations for legal-malpractice claims codified at G.L.1956 § 9-1-14.3 because plaintiff's action was commenced more than three years since the incidents giving rise to it occurred.”
Mendes v. Factor, 41 A.3d 994 (R.I. 2012). “1956 § 9-l-13(a), 13 and that their negligence claims were barred by the three-year limitation for legal malpractice, as set forth in § 9-1-14.3. 14 On appeal, plaintiffs attempt to forestall the death knell for their claims by raising two related theories: the continuous course…”
Henry v. Sheffield, 856 F. Supp. 2d 345 (D.R.I. 2012). “R.I. Gen. Laws § 9-1-14.3(2). It is undisputed that Plaintiff Corinna learned in the fall of 2004 that a change was made to Captain Henry’s will (or to the codicil) that affected her interests.”
Zanni v. Voccola, 13 A.3d 1068 (R.I. 2011). “3(2), which says: “In respect to those injuries due to acts of legal malpractice which could not in the exercise of reasonable diligence be discoverable at the time of the occurrence of the incident which gave rise to the action, suit shall be commenced within three (3) years of…”
— R.I. Gen. Laws § 9-1-14.3(b) — 1 case
Centracchio v. Schechter, 692 A.2d 1200 (R.I. 1997).
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