Providence School Board v. Providence Teachers Union, Local 958, AFT, AFL-CIO

The parties in this case are before the Supreme Court on cross-appeals from a Superior Court judgment following a jury verdict in favor of the plaintiff, Matthieu W. Yangambi (plaintiff), on a single claim of employment discrimination based on national origin. The defendants, the Providence School Board and the City of Providence (defendants), have challenged the Superior Court justice's jury instructions on several grounds, and argue that the Superior Court justice: (1) applied an incorrect law concerning evidentiary presumptions in an employment discrimination case (2) improperly weighed the evidence and (3) invaded the province of the jury. The defendants also contend that the Superior Court justice erred when she vacated the jury's finding that the plaintiff failed to mitigate his damages. The Supreme Court affirmed the judgment in full. The Court declared that, although defendants did not articulate a nondiscriminatory reason for their adverse employment decision, they presented some evidence sufficient to overcome judgment as a matter of law. In regard to the jury instructions, the Court held that Superior Court justice did not err in applying the law of evidentiary presumptions or invade the province of the jury, because the defendants did not satisfy their burden of production. Finally, the Court was of the opinion that the trial justice did not erroneously vacate the jury's finding on mitigation of damages, as the plaintiff applied for many administrative positions within Providence and was not required to seek employment outside of that municipality.