Justia Rhode Island Supreme Court Opinion Summaries

The Town of North Providence hired Everett McCain and appointed him as a lineman in the communications division of the fire department. McCain subsequently sustained injuries during the performance of his duties. Accordingly, the Town rendered injured-on-duty (IOD) payments to McCain pursuant to R.I. Gen. Laws 45-19-1. Later, the Town ceased making payments to McCain on the ground that McCain was not a "sworn firefighter" and, for that reason, was ineligible to collect IOD payments. McCain filed a petition for a writ of mandamus, asserting his right to IOD benefits. The superior court denied the writ but granted declaratory relief in favor of McCain, concluding that McCain was qualified as a "firefighter" eligible to receive benefits under section 45-19-1. The Supreme Court affirmed, holding that, based on the clear and unambiguous language set forth in section 45-19-1(c), McCain met the definition of "firefighter" at the time of his injury for purposes of collecting IOD benefits under that statute. View "McCain v. Town of N. Providence" on Justia Law

Plaintiff James Casale was employed by Defendant City of Cranston when he was injured. During his incapacity, Plaintiff received injured-on-duty (IOD) benefits from the City. In accordance with its policy with Plaintiff, Plaintiff's insurer, Amica Mutual Insurance Company, tendered $100,000 in uninsured motorist benefits to Plaintiff minus the amount that the City paid to Plaintiff for IOD benefits. Plaintiff subsequently initiated this declaratory judgment action seeking a judicial determination that R.I. Gen. Laws 45-19-1.1, which requires that an employer be reimbursed out of the proceeds received from the third party, was inapplicable to his case and that the City was not entitled to reimbursement from uninsured motorist benefits Plaintiff recovered under the policy. The trial justice concluded that the City was not entitled to reimbursement. The Supreme Court affirmed, holding (1) the trial justice correctly held that Defendant was not entitled to reimbursement for the IOD payments paid to Plaintiff; and (2) because Plaintiff did not collect any money from the tortfeasor, section 45-19-1.1 was inapplicable to this case. View "Casale v. City of Cranston" on Justia Law

Plaintiff, a former police officer, filed an action against Defendants, the Town of Portsmouth, its then chief of police, and a now retired lieutenant, alleging several causes of action arising from an investigation into Plaintiff's conduct during an officer training exercise. The superior court entered judgment in favor of Defendants. The Supreme Court affirmed in part and vacated in part, holding (1) the trial justice properly granted judgment as a matter of law in favor of Defendants on the claims of malicious prosecution and tortious interference with contractual relations; but (2) the trial justice erred by granting Plaintiff's R.I. R. Civ. P. 12(b)(6) motion to dismiss the chief of police and lieutenant's counterclaim for defamation arising from an inflammatory letter that Plaintiff submitted to the town council to notify the council of his forthcoming suit in accordance with R.I. Gen. Laws 45-15-5 where (i) absolute privilege did not apply in this instance because the notice required by section 45-15-5 was not part of a judicial or quasi-judicial proceeding, and (ii) baseless claims and allegations made by parties who must provide notice under section 45-15-5 are not protected by absolute immunity under McDonald v. Smith. Remanded. View "Ims v. Town of Portsmouth" on Justia Law

Plaintiff Walter Moore appealed a grant of summary judgment in favor of the Defendants, the Rhode Island Board of Governors for Higher Education (Board of Governors) and the University of Rhode Island (URI). Plaintiff brought an employment discrimination suit against the Defendants in 2008, and in that suit, the record revealed that Plaintiff executed a waiver and release in which he released Defendants from liability for any lawsuits that arose from his employment with the Board of Governors. Plaintiffâs claim was then dismissed in the lower court. On appeal, the issue before the Supreme Court was whether that waiver-and-release applied to the URI as an agent of the Board of Governors. After reviewing the case records, the Supreme Court was not satisfied that the record reflected the waiver applied to the URI. The Court vacated the judgment of the lower court and remanded the case for further fact-finding proceedings.