Justia Labor & Employment Law Opinion Summaries

The Cumberland Teachers Association (union), appealed to the Supreme Court that confirmed an arbitrator's award in favor of the Cumberland School Committee (school committee). After protracted contract negotiations, the school committee and the union agreed on a three-year collective bargaining agreement (CBA) that would govern their relations for the 2006-2007, 2007-2008 and 2008-2009 academic years. "However, the parties soon discovered that they had left the negotiating table with two very different understandings of how a key component of their agreement would be implemented." An arbitrator was selected and the parties agreed that the issue to be decided by the arbitrator was whether “the Cumberland School Committee place[d] the aggrieved teachers at the correct salary level for the 2007-08 school year?” On appeal to the Supreme Court, the union argued that the arbitrator manifestly disregarded a contract provision when he found that there was no written agreement about how the new salary schedule would be implemented for the 2007-2008 year. Upon review, the Supreme Court concluded that the union did not demonstrate that the arbitrator manifestly disregarded the contract or that he was completely irrational in arriving at his decision and award.

Plaintiff, an African-American male of Nigerian origin, was hired by Atlantek, Inc. Zebra Technologies later acquired Atlantek. Three years later, Plaintiff was laid off. Plaintiff signed a release document and submitted it to Zebra Atlantek without consulting with his attorney. According to another document received by Plaintiff, Plaintiff's receipt of separation benefits was contingent on the receipt by Zebra Atlantek of a signed copy of the release document wherein Plaintiff released any claims under the Rhode Island Fair Employment Practices Act (FEPA) or any state law prohibiting employment discrimination or harassment. Plaintiff later commenced an action against Defendants, Zebra Atlantek and several individuals, alleging that he had been discriminated against in violation of the FEPA and State Civil Rights Act. Defendants counterclaimed, alleging that Plaintiff's filing of the lawsuit constituted a material breach of the release document. The superior court granted summary judgment in favor of Defendants. The Supreme Court affirmed, holding that the hearing justice did not err in granting summary judgment in favor of Defendants, holding that FEPA did not render the release document void as it applied to Plaintiff's pending FEPA claims.

Plaintiff, Defendant's employee, was traveling as a passenger in a pickup truck owned and operated by Defendant when the truck collided with another vehicle, resulting in injuries to Plaintiff. Plaintiff sued Defendant and Defendant's Insurer, alleging negligence. The trial justice granted summary judgment in favor of Defendant, reasoning that because Plaintiff had collected workers' compensation benefits for injuries sustained while traveling with Defendant on work-related business, the exclusivity provision of the Workers' Compensation Act precluded double recovery. The Supreme Court affirmed, holding that Plaintiff relinquished his right to sue Defendant in tort after accepting workers' compensation benefits based on the exclusivity provision of the Act.

Dennis Gallagher was diagnosed with malignant mesothelioma, an occupational disease, and ultimately succumbed to the disease. A trial judge of the workers' compensation court entered decrees holding USGEN New England, Inc. (USGEN) liable to pay benefits to Dennis and to his wife, Maureen Gallagher, as Dennis's last employer under R.I. Gen. Laws 28-34-8. The appellate division of the workers' compensation court vacated those decrees and entered final decrees assessing liability against National Grid USA/Narragansett Electric (National Grid), USGEN's predecessor as owner of the plant where Dennis had worked and been exposed to asbestos. Maureen and National Grid each petitioned for a writ of certiorari to review the appellate division's final decrees. The Supreme Court issued both writs and consolidated the cases. The Court then affirmed, holding that the appellate division did not err in vacating the trial judge's decrees and in entering final decrees assessing liability against National Grid instead.

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.

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.

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.

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.