Rhode Island Superior Court

Complaint for Breach of Contract

[// GUIDANCE: This template is drafted for use in the Rhode Island Superior Court. Adapt the caption for District Court if the amount in controversy is ≤ $10,000.]

TABLE OF CONTENTS

1. Caption ............................................................................................................................. 2
2. Preliminary Statement ............................................................................................. 3
3. Parties .......................................................................................................................... 3
4. Jurisdiction & Venue ............................................................................................... 4
5. Factual Allegations ................................................................................................. 4
6. Cause of Action – Breach of Contract .............................................................. 6
7. Damages .................................................................................................................... 6
8. Conditions Precedent & Compliance Statements ....................................... 7
9. Prayer for Relief ...................................................................................................... 8
10. Jury Demand ............................................................................................................. 9
11. Service & Discovery Certifications .................................................................. 9
12. Verification (Optional) ......................................................................................... 10

1. CAPTION

STATE OF RHODE ISLAND
SUPERIOR COURT [COUNTY] UNIT

[PLAINTIFF NAME], :
Plaintiff, :
:
v. : C.A. No. ____
:
[DEFENDANT NAME], :
Defendant. :

COMPLAINT FOR BREACH OF CONTRACT
JURY TRIAL REQUESTED

2. PRELIMINARY STATEMENT

1. Plaintiff [PLAINTIFF NAME] (“Plaintiff”) brings this action against Defendant [DEFENDANT NAME] (“Defendant”) for damages and equitable relief arising out of Defendant’s material breach of the written contract dated [CONTRACT DATE] titled “[CONTRACT TITLE]” (the “Contract”).
2. Plaintiff seeks compensation for monetary losses in excess of $[AMOUNT] together with prejudgment interest, costs, reasonable attorneys’ fees where allowed, and such other relief as the Court deems just and proper.

3. PARTIES

3. Plaintiff is a [type of entity or individual], organized and existing under the laws of [state of formation] with its principal place of business at [address].
4. Upon information and belief, Defendant is a [type of entity or individual] organized and existing under the laws of [state of formation] with its principal place of business at [address], and does business in the State of Rhode Island.

4. JURISDICTION & VENUE

5. This Court has subject-matter jurisdiction pursuant to R.I. Gen. Laws § 8-2-14 because the amount in controversy exceeds $10,000, exclusive of interest and costs.
6. Personal jurisdiction is proper because Defendant transacted business and contracted with Plaintiff in Rhode Island and committed the acts complained of herein within this State.
7. Venue is proper in the [COUNTY] Unit of the Rhode Island Superior Court under R.I. Gen. Laws § 9-4-3 because a substantial part of the events giving rise to Plaintiff’s claims occurred in this county and the Contract was to be performed here.

5. FACTUAL ALLEGATIONS

8. On or about [CONTRACT DATE], Plaintiff and Defendant entered into the Contract, a true and correct copy of which is attached as Exhibit A.
9. Under the Contract, Defendant was obligated to [describe key obligations—e.g., deliver 10,000 widgets conforming to specifications set forth in Schedule 1] no later than [performance deadline].
10. Plaintiff fully performed, or was ready, willing, and able to perform, all material obligations under the Contract.
11. Defendant materially breached the Contract by:
    a. Failing to [specific failure—e.g., deliver conforming goods];
    b. Delivering non-conforming goods despite written notice of defects dated [date]; and
    c. Refusing to cure within the contractual cure period of [number] days.
12. Plaintiff provided timely written notice of breach to Defendant on [notice date] pursuant to Section [__] of the Contract.
13. As a direct and proximate result of Defendant’s breaches, Plaintiff has suffered and continues to suffer damages, including but not limited to lost profits, cover costs, and incidental and consequential damages in an amount to be proven at trial but not less than $[AMOUNT].

6. CAUSE OF ACTION – BREACH OF CONTRACT

14. Plaintiff repeats and realleges Paragraphs 1 through 13 above as if fully set forth herein.
15. The Contract is a valid and enforceable agreement supported by adequate consideration.
16. Defendant materially breached the Contract as described above.
17. Defendant’s breaches have caused Plaintiff to incur damages in excess of $[AMOUNT].
18. Plaintiff is therefore entitled to judgment against Defendant for the full measure of its damages, together with all other relief permitted by law or equity.

7. DAMAGES

19. Compensatory Damages: At least $[AMOUNT] representing [describe—e.g., out-of-pocket costs, lost profits].
20. Incidental & Consequential Damages: Including costs of cover, storage, inspection, and lost business opportunities.
21. Pre-Judgment Interest: At the statutory rate pursuant to R.I. Gen. Laws § 9-21-10.
22. Attorneys’ Fees & Costs: As allowed by the Contract (Section [__]) and/or as otherwise permitted by law.
23. Equitable Relief: Specific performance, temporary and permanent injunctive relief preventing further breaches, and any other equitable relief this Court deems just and proper.

8. CONDITIONS PRECEDENT & COMPLIANCE STATEMENTS

24. All conditions precedent to the commencement of this action have occurred, been performed, or have been waived.
25. Plaintiff has complied with the notice requirements of R.I. Super. Ct. R. Civ. P. 11 and conducted a reasonable inquiry confirming that the allegations herein have evidentiary support.
26. Plaintiff will effectuate service of the Summons and this Complaint in accordance with R.I. Super. Ct. R. Civ. P. 4 within the 120-day period provided therein.

[// GUIDANCE: For closely-held corporate defendants, consider requesting appointment of a special process server under Rule 4(c)(2) for efficiency.]

9. PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in its favor and against Defendant as follows:

A. Awarding compensatory, incidental, and consequential damages in an amount to be determined at trial but not less than $[AMOUNT];
B. Awarding pre-judgment and post-judgment interest at the statutory rate;
C. Awarding costs of suit and reasonable attorneys’ fees where allowable;
D. Granting specific performance and/or injunctive relief compelling Defendant to [specific equitable relief];
E. Granting such other and further relief as the Court deems just and proper.

10. JURY DEMAND

Pursuant to R.I. Super. Ct. R. Civ. P. 38(b), Plaintiff demands a trial by jury on all issues so triable.

11. SERVICE & DISCOVERY CERTIFICATIONS

27. Pursuant to R.I. Super. Ct. R. Civ. P. 5(b)(2), service of all pleadings and papers after the original Complaint will be made through the Court’s electronic filing system (File & ServeXpress), or as otherwise ordered.
28. Plaintiff is aware of the proportionality guidelines of R.I. Super. Ct. R. Civ. P. 26(b)(1) and intends to tailor discovery requests accordingly.

[// GUIDANCE: To expedite discovery, consider including a proposed scheduling order with limited initial discovery—e.g., 25 interrogatories, 25 document requests, and 4 depositions per side—consistent with local practice.]

12. VERIFICATION (Optional – include if required by contract or statute)

I, [SIGNATORY NAME], being duly sworn, depose and say:
1. I am the [title/role] of Plaintiff and am authorized to make this verification.
2. I have read the foregoing Complaint and know the contents thereof.
3. The facts stated therein are true to the best of my knowledge, information, and belief.
[PLAINTIFF NAME]

By: ____
[SIGNATORY NAME], [Title]
Subscribed and sworn before me
this ___ day of __, 20__

Notary Public
My Commission Expires: _

13. SIGNATURE BLOCK

Respectfully submitted,

[PLAINTIFF NAME]

By: _____
[ATTORNEY NAME] (#RI Bar No. __)
[LAW FIRM NAME]
[Street Address]
[City, State ZIP]
Tel: () -
Fax: () -____
Email: [email address]

Dated: __, 20
[// GUIDANCE: Attach the Contract (and any amendments) as Exhibit A. Additional exhibits—e.g., demand letters, invoices—should be labeled sequentially (Ex. B, Ex. C, etc.).]

END OF DOCUMENT