R.I. Gen. Laws
Rhode Island General Laws

R.I. Gen. Laws § 9-1-20 (2026)

Time of accrual of concealed cause of action

✓ current as of July 2026
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If any person, liable to an action by another, shall fraudulently, by actual misrepresentation, conceal from him or her the existence of the cause of action, the cause of action shall be deemed to accrue against the person so liable at the time when the person entitled to sue thereon shall first discover its existence.

Notes of Decisions
Cited in 28 cases (3 in the last 5 years), 1968–2024 · leading case: Boudreau v. Automatic Temperature Controls, Inc., 212 A.3d 594 (R.I. 2019).
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Boudreau v. Automatic Temperature Controls, Inc., 212 A.3d 594 (R.I. 2019). · cites it 5× “B Fraudulent Concealment The plaintiff next argues that § 9-1-20 should toll the statute of limitations for his computer crime claims because, he alleges, ATC fraudulently concealed the existence of said claims.”
Smith v. O'connell, 997 F. Supp. 226 (D.R.I. 1998). · cites it 13× “Laws § 9-1-19. The hierarchy defendants also dispute the contention that their alleged failure to disclose prior sexual misconduct by the priests amounted to “fraudulent concealment” within the meaning of R.”
Ryan v. Roman Catholic Bishop of Providence, 941 A.2d 174 (R.I. 2008). · cites it 3× “Pursuant to the provisions of § 9-1-20, if a potential defendant fraudulently conceals a cause of action from a potential plaintiff, the statute of limitations is tolled until such time as the plaintiff discovers the existence of a cause of action.”
Sola v. Leighton, 45 A.3d 502 (R.I. 2012). · cites it 3× “Finally, the trial justice held that “[tjhere is absolutely no evidence that Detective Caruolo acted in any way to conceal the existence of a cause of action against him;” and, consequently, the trial justice refused to toll the statute of limitations pursuant to G.L.1956 §…”
Charles E. Fogarty v. Ralph Palumbo James Ottenbacher v. Ralph Palumbo, 163 A.3d 526 (R.I. 2017). · cites it 2× “The plaintiffs also argue that the hearing justice failed to address G.L. 1956 § 9-1-20, which provides accrual of causes of actions when any person "liable to an action by another, shall fraudulently, by actual misrepresentation, conceal from him or her the existence of the…”
Helen L. Hyde v. The Roman Catholic Bishop of Providence Jeffrey Thomas v. The Roman Catholic Bishop of Providence, 139 A.3d 452 (R.I. 2016). · cites it 4× “2 The plaintiffs’ counsel objected to the proposed order, not on the grounds that it was inadequate for discovery on plaintiffs’ repressed-memory claims, but because plaintiffs’ counsel asserted the right to conduct discovery on an intentional concealment tolling theory pursuant…”
Dawn M. Parrillo, Adm'x of the Est. of Daniel Santos v. Rhode Island Hosp., 202 A.3d 942 (R.I. 2019). · cites it 5× “Parrillo cites to G.L. 1956 § 9-1-20, which, she contends, tolls the statute of limitations if the defendant acted in any way to conceal the existence of a cause of action.”
Henry v. Sheffield, 856 F. Supp. 2d 345 (D.R.I. 2012). · cites it 6× “Defendants contend that R.I. Gen. Laws § 9-1-20 is not applicable to this case to toll the statute of limitations.”
Arnold v. R.J. Reynolds Tobacco Co., 956 F. Supp. 110 (D.R.I. 1997). · cites it 4× “10 Faced with this conclusion, plaintiffs suggest that R.I.Gen.Laws § 9-1-20, 11 which provides the limitations period for a concealed cause of action, tolls the statute of limitations in the present case.”
Joseph McNulty v. Kristen Chip, 116 A.3d 173 (R.I. 2015). · cites it 2× “The plaintiffs also argue that the statute of limitations should be tolled, pursuant to § 9-1-20, because defendants fraudulently concealed their alleged misconduct.”
Renaud v. Sigma-Aldrich Corp., 662 A.2d 711 (R.I. 1995). · cites it 3× “See § 9-1-20; 3 Benner v. J.H. Lynch & Sons, Inc.”
Young v. Park, 359 A.2d 697 (R.I. 1976). · cites it 2× “Section 9-1-20. It is clear from the face of the fourth amended complaint that none of the alleged acts or omissions of the later-added defendants took place within any of the statutory limitations.”
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