Justia Rhode Island Supreme Court Opinion Summaries

Articles Posted in Labor & Employment Law
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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

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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

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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

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The Supreme Court affirmed the judgment of the superior court in favor of Defendants, in their capacities as the state's general treasurer and the executive director of the Employees' Retirement System of the State of Rhode Island (collectively, ERSRI), holding that the trial court did not err.Plaintiff brought this action asserting a declaratory judgment claim and filing an administrative appeal challenging ERSRI's decision to implement an offset against disability benefits any amount paid or payable under the workers' compensation law and claiming estoppel to prevent recovery of more than $24,000 in overpayments. The trial justice granted partial summary judgment for ERSRI. The Supreme Court affirmed, holding that the trial court did not err in upholding ERSRI's decision to offset workers' compensation benefits paid pursuant to R.I. Gen. Laws 28-33-45 against disability retirement benefits payable to a member of the state retirement system. View "Tiernan v. Magaziner" on Justia Law

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The Supreme Court affirmed the judgment of the superior court in favor of Pascoag Fire District and Pascoag Fire and Rescue Association (the district) and International Association of Firefighters, Local 4908 (the union) (collectively, Defendants) in this action alleging breach of duty of fair representation and breach of contract, holding that there was no error.Plaintiff, a trained firefighter and emergency medical technician who worked for the district, brought this action after he was terminated based on his conduct and performance during a rescue run. Plaintiff began the grievance process between the district and the union, but the union informed Plaintiff that it had decided not to seek arbitration for his grievance. Plaintiff then brought this complaint. The trial court granted judgment in favor of Defendants. The Supreme Court affirmed, holding that there was no error in the trial justice's grant of summary judgment. View "Eddy v. Pascoag Fire District" on Justia Law

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The Supreme Court quashed the order of the district court that denied Appellant's request for attorneys' fees pursuant to R.I. Gen. Laws 28-44-57(c) after Appellant successfully appealed a denial of unemployment benefits, holding that "appeal" within section 28-44-57(c) encompasses lower court proceedings on the claimant's path to receiving benefits.Appellant in this case successfully challenged the denial of unemployment benefits by the Rhode Island Department of Labor and Training. Appellant filed a petition for counsel fees pursuant to section 28-44-57 for work performed in the appeal to the district court from the Rhode Island Department of Labor and Training (DLT). The district court denied the petition, concluding that Appellant was not entitled to attorneys' fees for work performed by his attorney in the district court. The Supreme Court quashed the district court's order and remanded the case, holding that when an attorney represents an unemployment benefits claimant in an unsuccessful appeal to the district court but subsequently prevails in the Supreme Court, section 28-44-57(c)(2)(iii) entitles the attorney to fees and costs for the proceedings in the district court. View "Beagan v. Rhode Island Department of Labor & Training, Board of Review" on Justia Law

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The Supreme Court quashed the decree of the Appellate Division of the Workers' Compensation Court (WCC) awarding attorneys' fees and costs to Petitioner, holding that the WCC's Appellate Division acted in excess of its statutory authority in concluding that R.I. Gen. Laws 45-21.2-9 conferred authority to award attorneys' fees in this case.Petitioner, a firefighter with the City of Woonsocket, sustained a work-related injury and applied for accidental disability retirement (ADR) benefits with Respondent, Municipal Employees' Retirement System of Rhode Island. Respondent denied Petitioner's ADR application, finding that Petitioner had failed to prove that is injury arose out of and in the course of his duties as a firefighter. On appeal, the trial judge granted Petitioner's petition seeking ADR benefits and awarded a counsel fee to Petitioner's counsel. The Appellate Division upheld the fee award and imposed an additional fee for counsel's work before the Appellate Division. The Supreme Court reversed, holding that the General Assembly has not conveyed specific statutory authority upon the WCC to award attorneys' fees and costs in successful ADR appeal claims. View "Koback v. Municipal Employees' Retirement System of R.I." on Justia Law

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The Supreme Court affirmed in part and vacated in part the judgment of the superior court revoking Appellant's pension benefits and denying his request for return of his retirement contributions paid into the Employees' Retirement System of the State of Rhode Island (ERSRI), holding that the superior court erred in part.The superior court revoked Appellant's pension benefits, denied his request for return of his retirement contributions paid to the ERSRI, and ordered that retirement payments made to his spouse be applied towards his restitution obligations. The Supreme Court vacated the judgment in part, holding that the trial justice (1) did not err in revoking Defendant's pension benefits; (2) did not err in declaring that Appellant's spouse was an innocent spouse and awarding pension payments; (3) erred in directing the spouse to pay her payments as an innocent spouse towards Defendant's restitution obligations; and (4) vacated the portion of the judgment declining to apply Appellant's pension contributions to his restitution obligations. View "Retirement Board of Employees' Retirement System of State of R.I. v. Randall" on Justia Law

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The Supreme Court affirmed the decision of the Retirement Board of the Employees' Retirement System of the City of Providence denying Petitioner's application for an accidental disability retirement, holding that the Board relied on legally competent evidence.Petitioner, a firefighter, injured his right shoulder while lifting a patient. After he had recovered, he sustained a second work-related injury to his right shoulder. When a doctor evaluation concluded that he could not return to working full duty Petitioner submitted an application for an accidental disability retirement. The Board denied the application. On appeal, Petitioner argued that the Board ignored the legally competent evidence before it when it denied his application for an accidental disability retirement. The Supreme Court disagreed, holding that some evidence supported the Board's decision. View "Starnino v. Employees' Retirement System of City of Providence" on Justia Law

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The Supreme Court affirmed the order of the superior court dismissing Plaintiff's complaint alleging that Defendant, Rhode Island Public Transit Authority (RIPTA), failed to compensate her for past workplace injuries, holding that the trial justice properly dismissed the complaint.The trial justice found that the superior court did not have jurisdiction over certain claims because they were committed to the Workers' Compensation Court, that Plaintiff did not properly articulate other claims, and that the complaint failed adequately to inform Defendant of the nature of Plaintiff's claims. The Supreme Court affirmed, holding that Plaintiff's claims on appeal were without merit. View "Barnes v. Rhode Island Public Transit Authority" on Justia Law