The Rhode Island Supreme Court has upheld a lower court's decision to grant a preliminary injunction against Artak Avagyan and Lee Beausoleil, the owners of a light industrial property, in favor of musicians Vanessa Carlton and John McCauley. The court's ruling, issued on April 2, 2026, addresses a dispute over excessive noise that the plaintiffs claim has disrupted their enjoyment of their home.
This case, filed under docket number 2025-0132-Appeal, centers on the owners of neighboring properties in Warwick, Rhode Island. The plaintiffs reside at 141 Post Road, which is located in a residential zone, while the defendants own the adjacent property at 175 Post Road, categorized as light industrial. The plaintiffs argue that the noise from the defendants' property constitutes a private nuisance, affecting their quality of life.
The dispute began when the plaintiffs filed a verified complaint on October 17, 2024, seeking both monetary damages and injunctive relief due to what they described as unreasonable noise from construction activities on the defendants' property. The plaintiffs reported that the noise began in July 2024, coinciding with the arrival of a crane company that conducted operations on the site. They claimed that the noise was so disruptive that it made it impossible to enjoy their home, which they had purchased just a few years prior.
During the preliminary injunction hearing, Vanessa Carlton testified about the persistent construction-related noises, which included beeping from vehicles, hammering, and sounds from heavy machinery. She described the situation as “absolutely maddening” and stated that her family could not enjoy their property as they had before the noise began. John McCauley, her husband, echoed her sentiments, saying that the noise made their time at home “unenjoyable and completely depressing.”
After hearing testimonies from multiple witnesses, including police officers who had responded to noise complaints, the hearing justice issued a ruling on November 14, 2024, granting the preliminary injunction. The court found that the plaintiffs had established a reasonable likelihood of success on the merits of their case, indicating that the noise constituted a private nuisance. The ruling specifically noted that the defendants had engaged in activities that created unreasonably loud noises, some exceeding the limits set by local ordinances.
The court stated, “The totality of the evidence offered by the seven witnesses presented by [plaintiffs] credibly establishes that from July through October of 2024, there were frequent periods of long continuous and unreasonably loud noises.” It also highlighted the emotional distress experienced by the plaintiffs, noting that their health and well-being were adversely affected by the noise.
In its ruling, the Rhode Island Supreme Court affirmed the lower court's decision, rejecting the defendants' arguments that the hearing justice had erred in granting the injunction. The court ruled that the plaintiffs had demonstrated a likelihood of success on the merits of their private nuisance claim and that they would suffer irreparable harm without the injunction. The defendants had contended that the plaintiffs chose to live in an industrial area and should expect some level of noise, but the court found that the plaintiffs' home was in a residential historic district and that the noise issues arose after they purchased the property.
The Supreme Court also addressed the defendants' claims regarding federal regulations on noise, stating that the evidence showed that the noise was not limited to reverse signal alarms from construction vehicles, but included various other disruptive sounds. The court concluded that the hearing justice did not err in ruling on the likelihood of success or in finding that the plaintiffs would suffer irreparable harm without the injunction.
This ruling has significant implications for property owners and businesses operating near residential areas. It reinforces the importance of adhering to local noise ordinances and highlights the legal protections available to residents who experience disturbances from neighboring properties. The decision may also set a precedent for similar cases involving noise complaints and private nuisance claims, emphasizing the balance between industrial activities and residential peace.
Looking ahead, it remains to be seen whether the defendants will seek further legal recourse. While the Supreme Court's ruling is final, the defendants could potentially explore other avenues, such as appealing specific aspects of the injunction or seeking modifications based on changes in their operations. However, no additional related cases were mentioned in the court's opinion.