Justia Labor & Employment Law Opinion Summaries

Articles Posted in Rhode Island Supreme Court
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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

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The Supreme Court vacated the judgment of the superior court dismissing Plaintiffs' petition alleging that the City of Providence violated the terms of two superior court consent judgments entered in 2004 and seeking to enforce those judgments and to hold the City in contempt, holding that the City violated separation-of-powers principles.Plaintiffs, a retired firefighter and two retired police officers, filed a petition to enforce the 2004 consent judgments and hold the City in contempt of those judgments. The trial justice granted summary judgment for the City, finding that a pension ordinance passed in 2012 modified Plaintiffs' rights under the consent judgments. Plaintiffs appealed, arguing that a consent judgment cannot be overruled or otherwise modified by city ordinance. The City countered that the court would have violated separation of powers principles by finding it in contempt because courts cannot restrain municipal bodies from exercising their legislative powers. The Supreme Court vacated the judgment, holding (1) by enacting the pension ordinance, the City attempted to alter a superior court decision entered in the form of the consent judgment and thereby infringed on the exercise of judicial power; and (2) therefore, to the extent that the pension ordinance purported to nullify the consent judgment, it violated separation-of-powers principles embodied in the state constitution. View "Quattrucci v. Lombardi" on Justia Law

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The Supreme Court affirmed the decision of the Appellate Division of the Workers' Compensation Court affirming the decree of the trial judge that Petitioner had failed to prove that he sustained a neck injury arising out of and in the course of his employment, holding that legally competent evidence supported the Appellate Division's determination.Before the Supreme Court, Petitioner argued that the trial judge committed reversible error by stating that Dr. Thomas Rocco, M.D. was not qualified to opine on an orthopedic issue because he was a board certified general surgeon, not a board certified orthopedic surgeon, and finding Dr. Rocco's testimony to be inconsistent. The Supreme Court affirmed, holding (1) the Appellate Division did not err in upholding the trial judge's decision to discount Dr. Rocco's testimony; and (2) there was legally competent evidence to support the conclusion of the Appellate Division that Dr. Rocco's testimony was inconsistent. View "Thompson v. Millard Wire Co." on Justia Law

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In this action challenging an ordinance passed in 2011 requiring retirees from the City's police and fire departments to enroll in the federal Medicare program upon reaching the age of eligibility instead of continuing to have the City pay for their private health insurance for life the Supreme Court affirmed in part and vacated in part the final judgment of the superior court in favor of the City, holding that the trial judge misconceived the evidence with respect to the health care benefits that Plaintiffs were receiving from the City.Most police or firefighter retirees filed suit challenging the ordinance, and many settled. Some retirees opted out of the settlement and pursued their claims through a bench trial. The trial justice found in favor of the City. The Supreme Court held (1) with respect to Plaintiffs' claims for breach of contract, violation of the Takings Clause, and promissory estoppel, the superior court's judgment was proper; and (2) as to Plaintiffs' Contract Clause claims, the trial justice overlooked or misconceived evidence in several crucial respects. The Court remanded the case with instructions to enter judgment consistent with the provisions pertaining to the Medicare Ordinance as set forth in the final and consent judgment in the lawsuit from which Plaintiffs opted out. View "Andrews v. Lombardi" on Justia Law

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The Supreme Court affirmed the judgment of the superior court in favor of Defendants, including a Union and an Employee, and ordering the City of Cranston to arbitrate the Union's grievance filed on behalf of Employee after the trial justice found that Employee, a police officer, remained a member of the bargaining unit, holding that the trial justice did not err.After ending Employee's injured-on-duty benefits, the City terminated his employment. The Union filed a grievance alleging that the City's actions violated the collective bargaining agreement between the Union and the City. The City denied the grievance, and the Union filed a demand for arbitration under the collective bargaining agreement. When a dispute arose about whether an arbitrator should make the determination of whether the dispute was arbitrable the trial justice decided that he should decide that issue because, if a determination was made that Employee was retired, then the Union's grievance would not be arbitrable. The trial justice ruled that Employee had not retired. The Supreme Court affirmed, holding (1) Employee did not retire, and therefore, the Union had standing to pursue a grievance on his behalf and its grievance was substantively arbitrable; and (2) therefore, the trial justice did not err in granting the Union's motion to compel arbitration. View "City of Cranston v. International Brotherhood of Police Officers, Local 301" on Justia Law

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The Supreme Court affirmed the judgment of the superior court in favor of Employer on Employee's claim that Employer had violated the Rhode Island employer drug testing statute, R.I. Gen. Laws 28-6.5-1(a)(1) when it required Employee to take a drug test, allegedly without reasonable grounds, and terminated him for his refusal to do so, holding that reasonable grounds existed for the request that Employee take a drug test.According to the complaint, Employer wrongfully demanded that Employee undergo drug and alcohol testing in violation of portions of chapter 6.5 of title 28 of the General Laws. After the close of the trial, the trial justice concluded that Employer had reasonable grounds to believe that Employee was under the influence of a controlled substance. The Supreme Court affirmed, holding that there were ample facts on the basis of which the trial justice could have reached the conclusion that reasonable grounds existed for Employer's request that Employee take a drug test, and therefore, the trial justice did not err or abuse her discretion. View "Colpitts v. W.B. Mason Co., Inc." on Justia Law

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The Supreme Court vacated the order of the superior court denying the motion filed by a teachers' union and Jennifer Leyden (collectively, the Union) to vacate an arbitration award and granting the City of Providence's motion to confirm the award, holding that the trial justice erred in holding that the decision of the Employees' Retirement System of Rhode Island (the Retirement Board) granting Leyden's application for an ordinary disability retirement retired Leyden as a matter of law.Leyden, a school teacher, was awarded workers' compensation benefits after she was assaulted by students. The Retirement Board later approved Leyden's application for an ordinary disability retirement. While she was receiving workers' compensation benefits, Leyden sought reinstatement to her former teaching position. However, the School Department considered her to be retired. The Union filed a grievance, and the matter proceeded to arbitration. The arbitrator ruled in favor of the School Department, concluding that the Retirement Board had retired Leyden when it granted her request for an ordinary disability pension, and therefore, the Union had no standing to represent her. The superior court confirmed the award. The Supreme Court vacated the superior court's order, holding that Leyden's grievance that she was denied an appointment for the upcoming academic year was substantively arbitrable. View "Providence Teachers' Union Local 958, AFT, AFL-CIO v. Hemond" on Justia Law

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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