Early Estates v. Housing Board of Review of Providence

174 A.2d 117 (1961)

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Early Estates v. Housing Board of Review of Providence

Rhode Island Supreme Court
174 A.2d 117 (1961)

DD

Facts

Early Estates, Inc. (plaintiff) owned a three-tenement house in the city of Providence (the city). The Rhode Island legislature passed 1956 R.I. Pub. Laws ch. 3715 (the statute), which authorized the city to establish minimum housing standards. The statute stated that these standards had to serve the purpose of making housing safe, sanitary, and fit for human habitation. Pursuant to the statute, the city enacted the Minimum Standards Housing Ordinance (the ordinance). The ordinance required property owners to provide hallway lights and hot-water facilities. In Early Estates’ property, the hallway did not have a rear light, and the third-floor tenement did not have hot-water facilities. The city determined that Early Estates was in violation of the ordinance. The Housing Board of Review of Providence (defendant) (the board) upheld the city’s determination and ordered Early Estates to provide a hallway light and hot-water facilities. Early Estates appealed.

Rule of Law

Issue

Holding and Reasoning (Paolino, J.)

Dissent (Roberts, J.)

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