Chavers v. Fleet Bank (RI), N.A.
Rhode Island Supreme Court
844 A.2d 666 (2004)
Facts
The Office of the Comptroller of the Currency (the comptroller) is the primary regulator of national banks. Fleet Bank (RI), N.A. (Fleet) (defendant) was a national bank operating in Rhode Island. Fleet offered credit cards to potential customers. A group of Fleet’s credit-card holders (the credit-card holders) (plaintiffs) alleged that Fleet used bait-and-switch tactics in its credit-card solicitations. The credit-card holders sued Fleet in the superior court in Rhode Island for breach of contract and for violations of the Rhode Island Deceptive Trade Practices Act. The superior court granted summary judgment in favor of Fleet and held that the comptroller has authority over Fleet’s credit-card solicitations, so Fleet is statutorily exempt from the Rhode Island Deceptive Trade Practices Act. A statutory exemption precludes application of a statute if the subject matter is covered by another statute. The credit-card holders appealed.
Rule of Law
Issue
Holding and Reasoning (Williams, C.J.)
Dissent (Flanders, J.)
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