Justia Rhode Island Supreme Court Opinion Summaries

This case revolves around the denial of a disability pension application by a former state trooper, James Donnelly-Taylor. The defendants are the State of Rhode Island, Division of the State Police, and the Colonel of the State Police and Governor in their official capacities. The trooper had been involved in an incident where he assaulted an individual he had arrested. Following this incident, he reported experiencing personal and work-related stress and was placed on injured-on-duty status. Later, he was indicted on one count of simple assault. He pleaded nolo contendere to the assault charge and was ordered to perform community service. The trooper remained out of work and was later diagnosed with post-traumatic stress disorder and major depressive disorder. He applied for a disability pension, which was denied by the superintendent of the state police.The superintendent's decision was appealed to the Superior Court, which found the denial to be arbitrary and capricious. The court remanded the case back to the superintendent for further consideration. The superintendent issued a supplemental decision, maintaining the denial of the disability pension. The Superior Court again found the superintendent's decision to be arbitrary and capricious and reversed the denial, instructing the superintendent to grant the trooper's request for a disability pension.The State of Rhode Island appealed the Superior Court's decision to the Supreme Court of Rhode Island. The Supreme Court reversed the Superior Court's decision, finding that the superintendent's denial of the disability pension was neither arbitrary nor capricious. The court held that the superintendent had reasonable grounds to conclude that the trooper's assault of the individual was not in the course of performance of his duties as a state police officer, and therefore his disabling injuries were not suffered in the course of performance of his duties. The case was remanded back to the Superior Court with instructions to enter judgment in favor of the defendants. View "Rhode Island Troopers Association v. State of Rhode Island" on Justia Law

The plaintiff, Dania Mateo, filed a case against Davidson Media Group Rhode Island Stations, LLC and several of its employees, which included 22 counts alleging violations of Rhode Island's Fair Employment Practices Act (RIFEPA) and Civil Rights Act (RICRA) as well as claims of sexual harassment, civil conspiracy, intentional infliction of emotional distress, negligent infliction of emotional distress, assault and battery, negligence, false imprisonment, defamation, and conspiracy to commit defamation. The case was pending for nearly 14 years.Mateo appealed a Superior Court decision granting partial summary judgment in favor of certain defendants. The defendants cross-appealed, arguing that the hearing justice erred in granting partial final judgment because he failed to make an express determination that there was no just reason for delay, as required by Rule 54(b) of the Superior Court Rules of Civil Procedure.The Supreme Court of Rhode Island found the defendants’ cross-appeal meritorious. The Court ruled that the hearing justice erred in granting partial final judgment because he failed to determine whether the criteria clearly set forth in Rule 54(b) had been satisfied. The Court held that the judgment must be vacated and the case remanded to the Superior Court for further proceedings. As a result, the Court did not reach the issues raised in the plaintiff's appeal. View "Mateo v. Davidson Media Group Rhode Island Stations, LLC" on Justia Law

The case involves plaintiff Angelo Riccitelli and defendant Town of North Providence, through its Finance Director, Maria Vallee. Riccitelli, a retired firefighter, filed a complaint against the town, alleging that it failed to pay him the full amount required by a collective bargaining agreement. The agreement required the town to provide Riccitelli with a "supplemental pension payment" equal to the difference between his pension and the "monthly net pay" that he received at retirement, less any pension deductions. The dispute centered around the interpretation of the term "monthly net pay."The Supreme Court of Rhode Island found that the Superior Court erred in granting summary judgment in favor of Riccitelli because the collective bargaining agreement was not in the record. The court emphasized that the entire contract must be reviewed to determine whether a provision is clear and unambiguous. Without the agreement in the record, Riccitelli failed to carry his initial burden as the party moving for summary judgment, leaving open a critical question of fact—the content of the collective bargaining agreement. The court vacated the judgment of the Superior Court and returned the record to the Superior Court for further proceedings. View "Riccitelli v. The Town of North Providence" on Justia Law

In this case, the plaintiff, Jordan Nissensohn, as the administrator of the Estate of Michael Nissensohn, filed a suit against University Medical Group (UMG), Dr. Alan Epstein, and Dr. Steven Sepe, alleging numerous claims including defamation, breach of contract, tortious interference with contractual relations, conversion, and violations of the Rhode Island Whistleblowers’ Protection Act (RIWPA). The Superior Court entered a judgment in favor of the defendants, granting summary judgment.The plaintiff, Dr. Michael Nissensohn, had been employed as a gastroenterologist by UMG and was supervised by Dr. Epstein. The plaintiff had a series of disagreements and conflicts with Dr. Epstein over teaching responsibilities and alleged discrepancies in teaching compensation. The plaintiff also claimed that Dr. Epstein had disclosed his mental health information to another staff member, and had spread a rumor about his mental health. Additionally, the plaintiff claimed that Dr. Epstein interfered with his prospective business relations with patients and his contract, and converted his personal laptop.The Supreme Court of Rhode Island affirmed the judgment of the Superior Court. The court held that the plaintiff did not demonstrate that he engaged in protected conduct under the RIWPA because he did not report actual violations of the law. The court also ruled that the plaintiff's defamation claim abated upon his death and therefore did not survive. Regarding the breach of contract claim, the court found that the plaintiff failed to provide evidence of a breach of the written agreement. The court further held that the plaintiff failed to show that Dr. Epstein intended to harm his contract, which was an essential element of his claim for tortious interference. Lastly, the court found that the plaintiff failed to provide any non-hearsay evidence to prove his demand and refusal, thus failing to establish his claim for conversion. View "Nissensohn v. CharterCARE Home Health Services" on Justia Law

This case involves a dispute between Griggs & Browne Pest Control Co., Inc. (plaintiff), and its former employee, Brian Walls (defendant). Upon hiring Walls in 2011, the parties entered into a noncompetition agreement, which was updated in 2020. The agreement stipulated that, in return for his training and access to the company's client list, Walls would refrain from soliciting business from or performing services for the company's current or former customers for 24 months after ending his employment with the company.In 2021, the company introduced a new policy requiring all employees to receive the COVID-19 vaccination or terminate their employment. Walls vocally opposed the policy and was told he could no longer resume his employment. A month later, the company discovered that Walls was contacting their former clients and performing pest-control services for them, in violation of the noncompetition agreement. The company initiated a lawsuit to prevent Walls from further violating the agreement.The Superior Court of Rhode Island granted a preliminary injunction in favor of the plaintiff, which Walls appealed. The Supreme Court of Rhode Island affirmed the lower court's decision, determining that the noncompetition agreement was valid and enforceable. The court rejected Walls' argument that he had been improperly terminated due to his refusal to receive the COVID-19 vaccine, noting that the circumstances surrounding his departure were immaterial to the enforcement of the noncompetition agreement. The court also found that the plaintiff would suffer irreparable harm due to loss of customer goodwill if Walls were allowed to continue servicing the company's clients. The balance of equities favored the plaintiff, and the injunction was necessary to uphold the status quo. Therefore, the court affirmed the lower court's decision to grant a preliminary injunction in favor of the plaintiff. View "Griggs & Browne Pest Control Co., Inc. v. Walls" on Justia Law

The Supreme Court affirmed the judgment of the superior court in favor of Plaintiff and declaring that the City of Woonsocket improperly terminated Plaintiff's employment with the Woonsocket Police Department in violation of R.I. Gen. Laws 42-28.6-4 of the Law Enforcement Officers' Bill of Rights (LEOBOR), holding that there was no error.The order appealed from declared that the city's termination of Plaintiff's employment was unlawful in violation of section 42-28.6-4 of the LEOBOR and that the City must comply with LEOBOR's procedural requirements if it wished to terminate Plaintiff's employment. The Supreme Court affirmed, holding that the trial justice properly determined that the City improperly terminated Plaintiff's employment and improperly deprived him of the requisite notice and hearing. View "Sosa v. City of Woonsocket" on Justia Law

The Supreme Court vacated the judgment of the superior court in favor of Defendant, in his capacity as the finance director/treasurer for the Town of Smithfield, in this action challenging the calculation of a former employee's retirement benefits, holding that the court erred in concluding that Plaintiff had failed to exhaust his administrative remedies.Armand Beaudry worked as a firefighter for the Town for several years before he was placed on disability retirement benefits. The retirement benefits were governed by a pension system that constituted "an amalgamation of various documents." The case arose from a dispute over the calculation of Beaudry's benefits. Beaudry filed a complaint challenging the amount. The trial court granted the Town's motion for summary judgment based on failure to exhaust administrative remedies. The Supreme Court vacated the judgment, holding that the hearing justice erred by finding that a challenged amendment to the plan was enforceable at the time of Beaudry's retirement, thus creating an administrative remedy that Beaudry failed to exhaust. View "Beaudry v. Rossi" on Justia Law

The Supreme Court affirmed the order of the superior court denying Petitioner's petition for a writ of mandamus and dismissing his complaint pursuant to Sup. Ct. R. Civ. P. 12(b)(1) and 12(b)(6), holding that the superior court did not err.Plaintiff, a former employee of the City of East Providence, attempted to rescind an agreement he made with the City regarding, among other things, his retirement benefits and the issuance of a corrected W-2 to reflect his injured-on-duty status. The trial judge entered judgment for the City. Plaintiff then filed a complaint and petition for a writ of mandamus against his union asking the superior court to abrogate agreement regarding the period of his injured-on-duty status. The trial court granted Defendants' motion to dismiss. The Supreme Court affirmed, holding (1) several of Plaintiff's arguments were waived; and (2) this case was barred by res judicata. View "Jenkins v. City of East Providence" on Justia Law

The Supreme Court affirmed the judgment of the superior court in favor of Defendant-union and denying Plaintiff's motion to vacate an arbitration award, granting Defendant's motion to confirm the award, and awarding attorneys' fees to Defendant as the prevailing party, holding that there was no error.Defendant represented certain municipal employees employed by Plaintiff, West Warwick Housing Authority. After Plaintiff suspended the employment of the grievant, Defendant grieved her termination pursuant to the parties' collective bargaining agreement (CBA). The arbitrator decided in the grievance's favor. Thereafter, Plaintiff filed a complaint seeking to vacate the arbitration award, arguing that the grievance was not substantively arbitrable because the CBA was invalid and that the arbitrator's decision was irrational. The superior court entered judgment in favor of Defendant. The Supreme Court affirmed, holding that the trial justice correctly denied Defendant's motion to vacate because the dispute was arbitrable. View "West Warwick Housing Authority v. R.I. Council 94" on Justia Law

The Supreme Court vacated the judgment of the superior court in favor of Defendant, the Fraternal Order of Police, Lodge 13 (the Union), in which the Court denied the Town of North Providence's petition to vacate an arbitration award and granted the Union's motion to confirm the award, holding that the arbitrator so imperfectly executed his authority that he did not provide a mutual, final, and definite award upon the subject matter, as required under R.I. Gen. Laws 28-9-18(a)(2).This action arose from a dispute between the Union and the Town regarding the effect of a collective bargaining agreement (CBA) governing the employment relationship between the Town and the Town's police officers. The arbitrator found in favor of the Union, and the superior court granted the Union's motion to confirm the award. The Supreme Court reversed, holding that the arbitrator's award failed to draw its essence from the contract, manifestly disregarded relevant portions of the CBA, and produced completely irrational results. View "Town of North Providence v. Fraternal Order of Police, Lodge 13" on Justia Law