In Ryan v. State of Rhode Island,. 420 A.2d 841 (1980), the plaintiffs alleged that certain state entities were negligent in reinstating Ryan's driver's license without making a statutorily required investigation of his character, habits, and driving abilities when Ryan's license had been subject to three suspensions.

The trial court dismissed the plaintiff's complaint.

The Supreme Court of Rhode Island affirmed the dismissal on the ground that "in suits brought against the state, plaintiffs must show a breach of some duty owed them in their individual capacities and not merely a breach of some obligation owed the general public." Id. at 843.