Justia Rhode Island Supreme Court Opinion Summaries

When James Maddalena, a correctional officer with the Department of Corrections (DOC), admitted that another officer was smoking marijuana, in his presence, while on duty, Maddalena was terminated from employment with the DOC. The Rhode Island Brotherhood of Correctional Officers (RIBCO) filed a grievance on behalf of Maddalena in accordance with its collective bargaining agreement (CBA), contending that Maddalena was terminated without just cause. The matter proceeded to arbitration. An arbitrator determined that there was not just cause for Maddalena’s termination and provided that Maddalena be suspended without pay for sixty days. A justice of the superior court granted the DOC’s motion to vacate the arbitration award and denied RIBCO’s motion to confirm the award, determining that the arbitrator exceeded his authority and reached an irrational result because his decision was based upon a manifest disregard of the CBA. The Supreme Court affirmed, holding that the trial justice did not err in concluding that the arbitrator manifestly disregarded the CBA and that the arbitration award was irrational. View "State Dep’t of Corr. v. R.I. Brotherhood of Corr. Officers" on Justia Law

The consolidated appeals arose out of a dispute between the Town of Johnston and Plaintiffs, former Town police officers who retired on injury disability. Plaintiffs filed complaints seeking declaratory and injunctive relief regarding entitlement to funds held in certain accounts. The Town refused to authorize distribution of amounts credited to the respective accounts, which were owned by the Town but maintained with Plaintiffs’ names and social security numbers. The superior court denied the Town’s motion for summary judgment and granted Plaintiffs’ cross-motions for summary judgment. The Supreme Court vacated the judgment of the superior court, holding that summary judgment in favor of Plaintiffs was not warranted because there were a multitude of factual issues that must be resolved. View "Ross v. Town of Johnston" on Justia Law

Frank Corrente was employed by the City of Providence during two separate time periods. Following a federal investigation, Corrente was convicted of six felony counts stemming from his employment during the second time period. After a hearing conducted pursuant to the “Honorable Service Ordinance” (HSO) of the City of Providence Code of Ordinances, the Retirement Board of the Employees’ Retirement System of the City of Providence voted to reduce Corrente’s pension benefits. The Board then filed a civil action in the superior court requesting a confirmation of its decision. The mayor and the City of Providence were allowed to intervene. The superior court subsequently entered an order confirming the Board’s decision to reduce Corrente’s pension. The intervenors appealed. The Supreme Court vacated the judgment of the superior court, holding that because this case was brought pursuant to the HSO and was adjudicated in the superior court prior to the enactment of R.I. Gen Laws 36-10.1-5, which vests the superior court with jurisdiction to review pending proceedings under a municipal ordinance, the superior court lacked subject-matter jurisdiction and, therefore, the final judgment was void. Remanded. View "Ret. Bd. of Employees’ Ret. Sys. of City of Providence v. Corrente" on Justia Law

These consolidated appeals concerned a highly contested labor dispute between the Town of North Kingstown and the North Kingstown Firefighters, Local 1651, International Association of Firefighters, AFL-CIO (“union”). At the heart of the litigation was the town’s unilateral implementation of a three-platoon structure and the effects of that reorganization, including a change to a twenty-four hours on, forty-eight hours off schedule. The superior court issued various declaratory and injunctive relief. The Supreme Court affirmed in part, and reversed and remanded in part, holding (1) the town’s actions in implementing its decision to change to a three-platoon structure were lawful under the circumstances; but (2) provided that the union complies with the requirements of the Firefighters Arbitration Act and makes timely requests, the town must bargain regarding the effects of its decision to implement the three-platoon structure. View "Town of North Kingstown v. Int’l Ass’n of Firefighters, Local 1651" on Justia Law

In 2000, Plaintiff filed a suit against Defendant in her capacity as Treasurer and Finance Director of the Town of Cumberland, alleging age discrimination in hiring and retaliation. After a trial, a verdict was returned for Plaintiff on both counts. Upon motion by Defendant, however, the verdicts were vacated and a judgment as a matter of law was entered for Defendant on both counts. Alternatively, the trial justice granted Defendant’s motions for a new trial on both claims. The Supreme Court vacated the trial justice’s finding on the discrimination claim. On remand, the case was retried before a second jury. The jury returned a verdict for Defendant. Plaintiff filed a motion for a new trial, which the trial justice denied. The Supreme Court affirmed, holding (1) the trial justice did not abuse her discretion in disallowing questioning on portions of a 1999 letter from Defendant’s counsel to the Commission of Human Rights; (2) the trial justice’s refusal to impart a jury instruction on a federal regulation and a state statute did not misconstrue the law; and (3) the judge did not err in now allowing Plaintiff to present evidence of his retaliation claim. View "McGarry v. Pielech" on Justia Law

Respondents, two firefighters, objected to orders from their superiors that they serve as part of the crew of a fire engine in the 2001 Pride Parade. Notwithstanding their objections, Respondents were ordered to cary out the task assigned, and they reluctantly took part in the parade. Thereafter, Respondents sued Petitioners, the former Providence Mayor and former Chief of the Providence Fire Department, as well as the City of Providence, on a variety of state and federal claims. Petitioners moved for summary judgment on two of those claims, invoking the doctrine of qualified immunity from suit. The superior court denied the motion for summary judgment. The Supreme Court quashed the judgment of the superior court, holding that, in view of the facts of this case, it was not necessary to invoke the doctrine of qualified immunity because no constitutional violation occurred. Remanded with instructions that Petitioners’ motion for summary judgment be granted. View "Fabrizio v. City of Providence" on Justia Law

Pawtucket police officer Laprade was convicted of disorderly conduct, stemming from a 2010 incident, during which two women observed the off-duty Laprade masturbating and exposing himself while driving his personal vehicle. The city charged Laprade with violations of regulations stemming from that conviction and other incidents, including sleeping while on duty. After being notified of the city’s recommendation that his employment be terminated, Laprade requested a hearing under the Law Enforcement Officers’ Bill of Rights Act (LEOBOR), G.L. 42-28.6-4. A committee was selected. Nine days before the scheduled hearing and one day after the statutory deadline, the city provided Laprade with a list of its witnesses and evidence. Because of the timing and a personal conflict, a member of the committee unsuccessfully sought a continuance. Although no complaint or petition had been filed, the Presiding Justice of the Superior Court issued an order stating that failure to present the list 10 days before the hearing date did not present good cause to extend the date. The committee refused to accept evidence on the first scheduled date. Ultimately the committee found that, due to procedural errors, the city had not proven its case. The superior court affirmed. The Rhode Island Supreme Court vacated, based on procedural errorsView "City of Pawtucket v. Laprade" on Justia Law

David Alba was appointed to serve as principal of an elementary school in Cranston, Rhode Island. Alba and the Cranston School Committee subsequently entered into an employment contract. Later, after a hearing, the Committee rejected a recommendation to renew Alba’s employment contract. Alba appealed the Committee’s decision. The Commissioner of Education denied and dismissed Alba’s appeal, concluding that Alba had received all the process to which he was entitled under the contract and the School Administrators’ Rights Act. The Board of Regents affirmed the Commissioner’s decision. The Supreme Court affirmed, holding (1) the Committee acted within its authority when it voted against the recommendation to renew Alba’s contract; and (2) the Committee’s nonrenewal of Alba’s contract did not deprive Alba of his rights under the Administrators’ Rights Act. View "Alba v. Cranston Sch. Comm." on Justia Law

Plaintiff, a member of the Rhode Island National Guard, was hired by the Department of Corrections (DOC) in 1988. In 2000, Plaintiff left his full-time employment at the DOC to report for active duty with the National Guard. Plaintiff returned to the DOC after having been on military leave for six years. In 2003, Plaintiff filed a declaratory judgment action against the DOC, contending that he was subjected to discrimination based on his military status when the DOC denied him promotion on three separate occasions during the six-year period when he was on military leave. The superior court entered judgment in favor of the DOC. The Supreme Court affirmed, holding (1) the trial justice did not err in denying Plaintiff’s claim for a declaratory judgment where Plaintiff failed to show that his military status or resulting unavailability was a substantial or motivating factor in the DOC’s repeated decisions not to promote him; and (2) the trial justice did not overlook or misconceive relevant and material evidence in the case. View "Panarello v. State, Dep’t of Corr." on Justia Law

The Providence School Board (Board) provided health insurance to active employees and retirees. In 2006, the Providence Teachers Union (Union) filed a grievance protesting a difference in the increase of premium costs for retirees compared with a more modest increase in premium costs for active employees. The Union argued that the Board's action violated three provisions of the collective bargaining agreement (CBA) between the board and the union. An arbitrator ruled in the Union's favor, concluding that the Board violated the CBA by failing to include retirees and active employees in a single group when it calculated the healthcare premium rates. The trial justice vacated the arbitration award, concluding (1) the Union did not have standing to pursue a grievance on behalf of retirees, and (2) the issue of the calculation of the group premium rate was not arbitrable. The Supreme Court affirmed, holding (1) pursuant to Arena v. City of Providence and City of Newport v. Local 1080, the Union could not pursue this grievance on behalf of the retirees; and (2) because the Union had no standing to pursue this particular grievance, the grievance was not arbitrable. View "Providence Sch. Bd. v. Providence Teachers Union, Local 958" on Justia Law