RI Supreme Court Overturns Raisin Case concerning Prison Liability under Public Duty Doctrine

In a fascinating case – Thomas Adams v. RI Department of Correction – the plaintiff appealed from an order and judgment of the Superior Court granting summary judgment in favor of the defendant.  The plaintiff alleged that he became ill after ingesting a box of raisins distributed by the defendant as part of a federal food program administered by the state for the benefit of needy citizens.  The defendant argued that the public duty doctrine precluded its liability for any alleged tortious conduct and that no exception to that doctrine obtained in the instant case. The Supreme Court concluded that the government action at issue in this case – the storage and distribution of food – is an activity that private persons and corporations perform regularly.  As a result, the public duty doctrine does not serve to shield the defendant from liability in this case.  Thus, the Court vacated the Superior Court judgment granting summary judgment in favor of the defendant.


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