Justia Labor & Employment Law Opinion Summaries

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

Plaintiff, a state employee, filed an action against the State Department of Mental Health, Retardation and Hospitals (MHRH) alleging that MRH violated the Rhode Island Whistleblowers’ Protection Act (WPA) when it placed him on administrative leave with pay and required that he undergo an independent medical examination (IME). The superior court found in favor of Plaintiff. The Supreme Court vacated the judgment of the superior court, holding that the decision of the MHRH to place Plaintiff on paid administrative leave with the requirement that he undergo an IME was not an adverse employment action, and therefore, as a matter of law, the MHRH did not “discharge, threaten, or otherwise discriminate” against Plaintiff in violation of the WPA. View "Russo v. State, Dep't of Mental Health, Retardation and Hosps." on Justia Law

Defendant hired Plaintiff twice when Plaintiff was sixty-seven years old for brief periods of employment. When Plaintiff was sixty-eight, Defendant rehired her as a titles and registrations clerk. When Plaintiff was seventy-two years old, Defendant terminated her employment. Plaintiff filed an action against Defendant for unlawful age and disability discrimination in violation of the Fair Employment Practices Act. The superior court granted summary judgment for Defendant on both employment discrimination claims. The Supreme Court affirmed, holding that the trial justice did not err (1) in finding that Defendant met its burden of producing a legitimate nondiscriminatory reason for Plaintiff’s dismissal, and (2) in holding that Plaintiff failed to demonstrate that those reasons were merely pretextual. View "Bucci v. Hurd Buick Pontiac GMC Truck, LLC " on Justia Law

Plaintiff, a member of a union, filed a complaint against Defendant, her former employer, alleging that during her employment she was subjected to a hostile work environment on account of her race and color and that she was wrongfully terminated. Defendant filed a motion to stay proceedings, arguing that the proper forum for resolution of Plaintiff’s claims was binding arbitration as required by the collective bargaining agreement (CBA) between the union and Defendant. A hearing justice granted Defendant’s motion to stay and ordered that the matter be resolved through arbitration. Plaintiff appealed, arguing that the hearing justice’s decision was in error because the CBA’s arbitration provision did not preclude her from asserting her statutorily created rights under the Rhode Island Civil Rights Act (RICRA) and Rhode Island Fair Employment Practices Act (FEPA) in a judicial forum. The Supreme Court vacated the order of the superior court, holding that the CBA’s general arbitration provision, which contained no specific reference to the state anti-discrimination statutes at issue, did not constitute a clear and unmistakable waiver of Plaintiff’s right to a judicial forum in which to litigate her claims arising under the RICRA and the FEPA. Remanded. View "Weeks v. 735 Putnam Pike Operations, LLC" 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

Plaintiff filed a civil action against the City of Providence for personal injuries she suffered after a school bus she was operating fell into a sinkhole on a city roadway. The trial court found that the City was negligent and awarded Plaintiff $59,239 in damages. The Supreme Court affirmed, holding (1) the trial justice did not err in admitting certain affidavits into evidence because the affidavits were subscribed and sworn to under oath in the presence of a notary and therefore met legislative requirements; and (2) the trial justice did not abuse her discretion in ruling that the collateral-source rule excluded evidence of Plaintiff's receipt of workers' compensation benefits. View "Morel v. Napolitano" on Justia Law

This case involved a dispute between the R.I. Department of Corrections (DOC) and the certified bargaining unit for correctional officers and other DOC employees (the union). The dispute arose from the DOC's proposal to modify the weapons qualification component of the training program for correctional officers. The union filed a grievance, arguing that the training program could not modified without the approval of a training committee that had been created under the parties' collective bargaining agreement (CBA). An arbitrator ruled in the union's favor. The superior confirmed the arbitration award. The Supreme Court affirmed, holding (1) this dispute was arbitrable; and (2) the arbitration award must stand because the arbitrator's interpretation of the CBA was passably plausible, did not reflect a manifest disregard for the law, and was not irrational. View "State Dep't of Corr. v. R.I. Brotherhood of Corr. Officers" on Justia Law

Plaintiff was a business agent for a labor organization that represented former employees of the public library. On June 30, the library terminated the employment of thirty-eight union employees. Plaintiff filed a complaint with the Department of Labor and Training (DLT)'s Division of Labor Standards, alleging that the library had failed to pay the employees vacation pay that the employees had accrued at the time of their termination. A hearing officer concluded that the employee's vacation time accrued on July 1 of each fiscal year, and because the employees were not employed on that date, they were not entitled to vacation pay. Plaintiff appealed, The superior court dismissed the complaint for lacking of jurisdiction, ruling that Plaintiff's complaint was untimely filed. The Supreme Court quashed the decision of the superior court and remanded, holding (1) Rule 6 of the Superior Court Rules of Civil Procedure applies to the superior court's review of administrative decisions; and (2) under Rule 6, Plaintiff's complaint would have been timely filed. Remanded. View "McAninch v. State Dep't of Labor and Training " on Justia Law

Plaintiff filed suit against the State alleging statutory claims under the Rhode Island Fair Employment Practices Act, the Rhode Island Civil Rights Act, and the Rhode Island Whistelblowers' Protection Act. The State filed a motion to dismiss and a motion for summary judgment, arguing that the claims should be barred by the doctrine of res judicata because Plaintiff had previously filed a nearly identical suit in federal court, which dismissed the action. The superior court denied the State's motions. The Supreme Court quashed the decision of the superior court and remanded, holding that the federal court judgment was entitled to preclusive effect, and Plaintiff's claims were barred by res judicata. View "Huntley v. State" on Justia Law