Justia Rhode Island Supreme Court Opinion Summaries

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

The Supreme Court affirmed in part and vacated in part the order of the superior court granting declaratory and injunctive relief in favor of Plaintiff in this action brought under the Law Enforcement Officers' Bill of Rights (LEOBOR), holding that remand was required for an order complying with the provisions of R.I. Gen. Laws 42-28.6-4 and restoration of Plaintiff's salary and benefits to the status quo ante.Plaintiff filed a complaint against the Rhode Island Commerce Corporation, the Rhode Island Airport Corporation and related defendants (collectively, Defendants) seeking a judgment declaring that she was entitled to the rights and benefits set forth under LEOBOR and seeking reinstatement to her position as the deputy chief of the Rhode Island Airport Police Department (RIAPD). The Supreme Court vacated the judgment in part, holding (1) Plaintiff was entitled to the protections granted to law enforcement officers in the LEOBOR statute; and (2) because Defendants terminated Plaintiff in violation of section 42-28.6-4(a) Plaintiff was entitled to all of the salary and benefits she would have received had she not been wrongfully terminated. View "Ricci v. R.I. Commerce Corp." on Justia Law

The Supreme Court vacated in part the judgment of the superior court reversing the decision of the Board to revoke Plaintiff's pension, ordering the permanent reinstatement of the pension, and declaring the pension revocation ordinance of the Town of Narragansett to be unconstitutionally vague, holding that the Board failed to make findings of fact or conclusions of law to support its decision.Plaintiff was a police officer with the Narragansett Police Department for twenty-eight years prior to his retirement. After Plaintiff pled guilty to transferring obscene matter to a person under the age of sixteen years the Board voted to revoke his pension under the pension revocation ordinance. Plaintiff and his wife sued. The trial justice concluded that the Board had violated Plaintiffs' due process rights in several respects and erred in declaring the pension revocation ordinance to be unconstitutionally vague. The Supreme Court vacated the judgment in part and remanded the case, holding that the trial court failed to make competent factual findings on which to base an as-applied analysis of the constitutionality of the pension revocation ordinance. View "Riley v. Narragansett Pension Board" on Justia Law

The Supreme Court quashed the decree of the appellate division of the workers' compensation court denying and dismissing Petitioner's petition for surviving-spouse compensation benefits and funeral expenses, holding that the going-and-coming rule did not preclude Petitioner's recovery.At issue was whether the exception to the going-and-coming rule as it was articulated in Branco v. Leviton Manufacturing Company, Inc., 518 A.2d 621 (R.I. 1986) precluded recovery of workers' compensation dependency benefits for the fatal injuries Petitioner's husband sustained while traveling from his employer's facility to a separate parking lot that was leased but not owned by the employer. The trial judge found that Petitioner's claim was not barred by the going-and-coming rule because the Branco exception applied. The appellate division vacated the decision below, finding that the going-and-coming rule barred Petitioner's claim. The Supreme Court quashed the decree below, holding that the Branco exception was applicable to the instant case. View "Phillips v. Enterprise Rent-A-Car Co. of Rhode Island" on Justia Law

The Supreme Court affirmed the final judgment of the superior court in favor of Defendants due to Plaintiff's having failed to comply with her discovery obligations, which had earlier been the subject of a conditional order of dismissal, holding that there was no error.Plaintiff brought this complaint alleging that Defendants had discriminated against her in retaliation for her whistleblowing activities and that she was entitled to relief under the Rhode Island Whistleblowers' Protection Act. Ultimately, the hearing justice granted Defendants' motion for final judgment on the grounds that Plaintiff had, over a five-year period, repeatedly failed to comply with her discovery obligations. The Supreme Court affirmed, holding that the hearing justice acted within her discretion in ordering the entry of final judgment. View "Boss v. Chamberland" on Justia Law

In this action for declaratory judgment the Supreme Court reversed the judgment of the superior court denying Family Dollar Stores of Rhode Island, Inc.'s motion for summary judgment and granting summary judgment for Justin Araujo, the complainant in a proceeding before the Rhode Island Commission for Human Rights, holding that the hearing justice erred.Araujo filed a complaint with the Commission alleging that Family Dollar, his employer, had discriminated against him on the basis of an illness. The parties entered into a settlement agreement that included a release. At issue was whether the release unambiguously constituted a waiver by Araujo of his right to pursue all claims he could make against Family Dollar. The hearing justice granted summary judgment in favor of Araujo, entering judgment declaring that the release did not cover Araujo's discrimination claims. The Supreme Court reversed, holding that the release unambiguously precluded Araujo from pursuing a discrimination charge with the Commission. View "Family Dollar Stores of Rhode Island, Inc. v. Araujo" on Justia Law