DoCouto v. Blue Water Realty, LLC
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The plaintiff, Lourenco DoCouto, appealed a decision by the Superior Court of Rhode Island that dismissed his case against defendants Blue Water Realty, LLC and Louis Bachetti. The dispute centered around a property DoCouto claimed he had an option to purchase. DoCouto argued that the Superior Court erred in applying the doctrine of res judicata, dismissing his complaint for failure to timely serve defendants, and in determining that the District Court had jurisdiction over his equitable claims in the eviction proceedings.
The Supreme Court of Rhode Island affirmed the Superior Court's decision. The court found that the parties in the eviction proceedings were the same or in privity with the parties in the present case. It also determined that DoCouto’s counterclaim in the eviction proceedings had alleged the same facts and arose out of the same transactions as those set forth in the current complaints. Therefore, the doctrine of res judicata applied, barring DoCouto’s claims.
Moreover, the court disagreed with DoCouto’s claim that the District Court lacked jurisdiction over his equitable claims. As the eviction action pertained to a lease agreement, the court held that the District Court had the requisite jurisdiction over DoCouto’s equitable claims according to the Rhode Island statute. Lastly, the court rejected DoCouto’s argument that the District Court lacked jurisdiction over his request for compensatory damages for services rendered because the amount in controversy exceeded the statutory limit relative to District Court jurisdiction. The statutory maximum set forth had no bearing on the District Court’s subject matter jurisdiction over landlord-tenant cases such as this one.
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