William Coscina v. Craig J. DiPetrillo

Supreme Court of Rhode Island
186 A.3d 590 (2018)

ELI5:

Rule of Law:

Summary judgment is an improper remedy for a claim of adverse possession when there are genuine issues of material fact regarding the boundaries of the disputed property. An accurate description of the land being claimed is an essential element of the adverse possession claim itself, not a secondary issue to be resolved after a finding of liability.

Facts:

William and Cheryl Coscina owned property abutting the property of Craig and Rebecca DiPetrillo.
A dispute arose over two tracts of land, known as 'Cheryl's Front Pasture' and 'Cheryl's Back Pasture,' which were legally part of the DiPetrillo property.
Beginning in 1979, Cheryl Coscina claimed to have used the front pasture for farm animals and ATVs, and the back pasture by clearing brush, cutting trees, and mowing.
The Coscinas alleged they maintained a stone wall along the front pasture's boundary and installed metal posts along the back pasture's boundary.
The DiPetrillos purchased their property in October 2013.
Craig DiPetrillo testified that he also used the back pasture for cookouts, as a passageway to the woods, and that he cut the grass.
After a court hearing on the matter, the Coscinas were observed clearing land even further back on the back pasture, expanding the area in dispute.
The description and demarcation of the disputed areas submitted by the Coscinas changed multiple times during the dispute.

Procedural Posture:

William and Cheryl Coscina (plaintiffs) filed a complaint against Craig and Rebecca DiPetrillo (defendants) in the Rhode Island Superior Court (trial court), seeking title to two tracts of land by adverse possession.
The DiPetrillos filed an answer and a counterclaim to quiet title to the disputed property.
The Coscinas moved for summary judgment on their adverse possession claim.
The Superior Court hearing justice granted summary judgment in favor of the Coscinas on the adverse possession count, despite acknowledging that a genuine issue of fact existed as to the precise boundary lines.
The hearing justice then held an evidentiary hearing to resolve the factual dispute over the boundaries and subsequently entered a final judgment for the Coscinas.
The DiPetrillos (appellants) appealed the final judgment to the Supreme Court of Rhode Island, with the Coscinas as appellees.

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Issue:

Is a grant of summary judgment on a claim of adverse possession proper when a genuine issue of material fact exists regarding the precise boundaries of the land being claimed?

Opinions:

Majority - Justice Goldberg

No. A grant of summary judgment is improper for an adverse possession claim where genuine issues of material fact exist, particularly concerning the boundaries of the land claimed. Adverse possession claims are inherently fact-intensive and are generally not susceptible to resolution by summary judgment. The hearing justice erred by finding that adverse possession had been established while simultaneously acknowledging that 'there is an issue of fact as to what is the actual boundary line.' An accurate description of the claimed land is an essential element of the cause of action, not a detail to be determined after granting judgment. The lower court further erred by engaging in fact-finding at an evidentiary hearing to resolve the boundary dispute, a procedure not permitted at the summary judgment stage.

Analysis:

This decision strongly reinforces the principle that adverse possession claims are ill-suited for summary judgment due to their fact-intensive nature. It clarifies that the precise demarcation of the claimed property is a threshold material fact that must be undisputed for summary judgment to be appropriate. The ruling serves as a crucial procedural guardrail, preventing trial courts from bifurcating an adverse possession claim by granting judgment on the 'fact' of possession while leaving the essential element of the property's description to be determined later. This ensures that a defendant's property rights are not extinguished without a full trial when there are legitimate disputes over the scope of the plaintiff's claim.

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