Justia Labor & Employment Law Opinion Summaries

Articles Posted in Rhode Island Supreme Court
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The Supreme Court affirmed the judgment of the superior court entering summary judgment in favor of the Town of Johnston and dismissing Plaintiff's suit alleging claims of governmental promissory estoppel and deprivation of property rights after the Town denied Plaintiff's requests for health benefits set forth in Ordinance 767, holding that Plaintiff was not eligible to receive benefits under the ordinance. Plaintiff served on the Johnston Town Council from 1981 until 1994. In 1989, the Town passed and adopted Ordinance 767, which established various benefits for certain town officials. In 1993, Ordinance 767 was repealed by Ordinance 913. In the early 2000s Plaintiff made several demands on the Town for the health benefits set forth in Ordinance 767, arguing that his entitlement to those benefits had vested as of 1991. After the Town denied those requests Plaintiff filed suit. The superior court granted summary judgment for the Town. The Supreme Court affirmed, holding (1) the clear and unambiguous language of Ordinance 767 indicates that Plaintiff was not eligible to receive benefits under the ordinance; and (2) Ordinance 767 sought to create a right to health benefits that did not previously exist, and therefore, the enactment could not be deemed a remedial ordinance. View "Zanni v. Town of Johnston" on Justia Law

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The Supreme Court affirmed in part and quashed in part the final decree of the Workers' Compensation Court (WCC) upholding an award of accidental disability benefits for occupational cancer to Petitioner, holding that the WCC had jurisdiction to hear Petitioner's appeal but erred in finding that R.I. Gen. Laws 45-19.1-1 contains a conclusive presumption that all cancer in firefighters is occupational cancer. Petitioner served as a firefighter for the City of Cranston until he was diagnosed with colon cancer. Petitioner applied for accidental disability benefit based upon his cancer diagnosis. The Retirement Board of the Municipal Employees' Retirement System of Rhode Island denied the application, finding that Petitioner did not prove that his cancer arose out of and in the course of his employment as a firefighter. The WCC then filed his petition arguing that, pursuant to chapter 19.1 of title 45, all cancers contracted by firefighters are presumed to be work-related. The trial judge agreed and reversed the board. The Supreme Court quashed the decree in part, holding that chapter 19.1 of title 45 does not contain any presumption that all cancers in firefighters are occupational cancers. View "Lang v. Municipal Employees' Retirement System of Rhode Island" on Justia Law

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The Supreme Court affirmed the judgment of the superior court dismissing Plaintiff's complaint against Child and Family Services of Newport County (CFS) alleging defamation, constructive termination, discrimination, and breach of the covenant of good faith and fair dealing, holding that the hearing justice properly dismissed Plaintiff's claims. Specifically, the Court held (1) where the complaint did not allege that CFS made any false statements about Defendant, Plaintiff did not sufficiently allege a claim for defamation; (2) Plaintiff did not properly plead a claim for breach of the covenant of good faith and fair dealing; (3) the complaint did not include sufficient facts to allege a prima facie case of either employment discrimination or a civil rights violation; and (4) the hearing justice did not err in dismissing the amended complaint with prejudice. View "Ferreira v. Child and Family Services of Rhode Island" on Justia Law

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The Supreme Court vacated the judgment of the superior court that granted a preliminary injunction in favor of Plaintiffs restraining the City of Woonsocket from changing the terms of Plaintiffs' retiree health insurance, holding that the City had the statutory authority to make changes to Plaintiffs' health care benefits. Plaintiffs, several retried Woonsocket police officers, brought this action against the City and the Woonsocket Budget Commission (the WBC). The superior court granted a preliminary injunction for Plaintiffs and reinstated Plaintiffs' previous postretirement health care benefits. The Supreme Court vacated the judgment, holding that the trial justice (1) did not err when he found that Plaintiffs had a vested contractual right to free lifetime health care benefits; (2) erred when he found that the WBC lacked statutory authority when it adopted the Retiree Resolutions that required Plaintiffs to contribute to their health care expenses; and (3) erred in finding that the WBC violated the Contract Clause of the Rhode Island Constitution when it required Plaintiffs to pay for their health insurance under a new uniform health care plan applicable to all retirees and employees. The Court remanded the case to the trial justice for additional findings. View "Hebert v. City of Woonsocket" on Justia Law

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In this dispute over the cost of annual premiums for post-retirement life insurance benefits the Supreme Court affirmed the judgment of the superior court entering summary judgment in favor of Plaintiffs - the Rhode Island American Federal of Teachers/Retired Local 8307 and several retirees of the Johnston School Department - holding that the trial justice correctly interpreted R.I. Gen. Laws 16-16-42. Before the Supreme Court, both Plaintiffs and Defendants - the Town of Johnston, the Johnston School Department, the Johnston School Committee, and various municipal officials - argued that section 16-16-42, entitled "Life insurance benefits," is clear and unambiguous, but each party posited a different interpretation. The Supreme Court affirmed the decision of the superior court justice, holding that a proper interpretation of the statute provides that any teacher who, at the time of retirement from service or last day of active employment, has in effect life insurance provided for as a benefit of his or her employment shall, after retirement, be entitled to keep the life insurance policy in effect by paying to the municipality an amount equal to the annual cost of the policy for the individual at the time of the individual's retirement or last day of active employment. View "Rhode Island American Federation of Teachers/Retired Local 8037 v. Johnston School Committee" on Justia Law

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The Supreme Court affirmed the judgment of the superior court affirming a decision of the Rhode Island Department of Labor and Training (DLT) that denied Petitioners' wage and hour claims against Delta Airline, Inc., holding that the superior court did not err in affirming the DLT's finding that R.I. Gen. Laws 25-3-3 was preempted by federal law. Petitioners were customer service agents for Delta at its facility at the T.F. Green Airport in Warwick, Rhode Island. Petitioners filed separate individual "nonpayment of wages" complaints with DLT, alleging that Delta violated the provisions of section 25-3-3 by failing to pay Petitioners time-and-a-half for hours worked on Sundays and holidays. The hearing officer determined that section 25-3-3 was preempted by section 49 U.S.C. 41713(b)(1) of the Airline Deregulation Act (ADA). The superior court affirmed. The Supreme Court affirmed, holding that Petitioners' claims were preempted by the ADA. View "Brindle v. Rhode Island Department of Labor & Training" on Justia Law

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The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Defendants on the grounds that the case was moot, holding that there was no justiciable controversy before the Court and that Plaintiffs failed to meet the burden of demonstrating that the issues raised in their complaint were of extreme public importance and were capable of repetition yet will evade review. After the National Education Association Rhode Island and the Middletown Teachers' Association/NEA (collectively, the Union) and the Middletown School Committee (school committee) reached a tentative successor agreement to a collective bargaining agreement (CBA) that was due to expire the Town of Middletown refused to ratify the agreement. The Union filed suit challenging the denial. Thereafter, the parties agreed to a new three-year CBA, and the Town voted to ratify the agreement. The trial justice granted summary judgment for Defendants, the Town, the school committee, and the Middletown School Department. The Supreme Court affirmed, holding that the trial justice did not err in granting summary judgment on the basis of mootness and that no exceptions to the mootness doctrine existed. View "National Education Ass'n Rhode Island v. Town of Middletown" on Justia Law

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In this appeal concerned two City of Cranston ordinances that promulgated a ten-year suspension of the cost-of-living adjustment benefit for retirees of the Cranston Police Department and Cranston Fire Department who were enrolled in the City's pension plan the Supreme Court affirmed the judgment of the superior court finding in favor of Defendants, holding that the superior court did not err in its judgment. The Cranston Police Retirees Action Committee (Plaintiff) brought this action against the City, Mayor Allan Fung, and members of the Cranston City Council (collectively, Defendants) alleging claims ranging from constitutional violations to statutory infringements. A superior court justice found in favor of Defendants on all counts. The Supreme Court affirmed, holding that the superior court justice did not err by (1) finding that the ordinances did not violate the Contract Clauses of the United States and Rhode Island Constitutions; (2) applying the burden of proof in the Contract Clause analysis; (3) applying expert testimony; (4) granting summary judgment for the City as to Takings Clause, res judicata, and Rhode Island Open Meetings Act claims; and (5) ruling on an assortment of motions and in her findings of fact and conclusions of law. View "Cranston Police Retirees Action Committee v. City of Cranston" on Justia Law

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The Supreme Court affirmed the decision of the Retirement Board of the Employee Retirement System of Providence (the Board) denying Petitioner's application for accidental disability retirement benefits and instead awarding her ordinary disability benefits, holding that there was legally competent evidence supporting the Board's decision to deny Petitioner accidental disability retirement benefits. Petitioner, who served as a bus monitor for the City of Providence, submitted an application for accidental-disability retirement benefits to Respondent, the Employees' Retirement System of Providence, alleging that she had suffered a work-related injury. The Board denied Petitioner's application and instead granted Petitioner ordinary disability benefits. The Supreme Court affirmed, holding that the Board based its decision on legally competent evidence that Petitioner's employment was not the natural and proximate cause of her disability. View "Trinidad v. Employees' Retirement System of Providence" on Justia Law

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The Supreme Court vacated the September 20, 2016 judgment of the superior court entering judgment against Family Dollar Stores of Rhode Island, Inc. and affirmed the November 9, 2016 order of the superior court granting Family Dollar's emergency motion for a thirty-day extension of time within which to file its notice of appeal, holding that the hearing justice erred in dismissing Family Dollar's declaratory judgment action. Family Dollar filed this action against Justin B. Araujo seeking a declaratory judgment that the parties had entered into an enforceable settlement agreement releasing Family Dollar from claims that Araujo asserted against it in his charge before the Rhode Island Commission for Human Rights and also alleging breach of contract. The Commission was added as an additional party to the case. The hearing justice granted Defendants' motions to dismiss on the basis that the proper forum for this action was before the Commission. Family Dollar later filed an emergency motion for a thirty-day time extension, which the hearing justice granted. The Supreme Court affirmed in part and vacated in part, holding (1) the hearing justice did not abuse his discretion in finding excusable neglect in this case; and (2) Family Dollar's declaratory judgment action may proceed in superior court on remand. View "Family Dollar Stores of Rhode Island, Inc. v. Araujo" on Justia Law