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.

The plaintiff, Jane Doe, appealed from a Superior Court judgment dismissing her complaint against the defendants, Brown University and two of its employees. In Superior Court, the plaintiff asserted claims under both the Rhode Island Civil Rights Act (RICRA) and article 1, section 2 of the Rhode Island Constitution. On appeal, the plaintiff argued that the hearing justice erred in determining that her claims under RICRA were precluded by the prior dismissal of the plaintiff's federal Title IX claim. The plaintiff also argued that the hearing justice erred in holding that section 2 of article 1 of the Rhode Island Constitution does not grant the plaintiff a private right of action. The Supreme Court first held that the plaintiff's claims under RICRA were predicated upon the defendants' alleged violations of Title IX, which had already been litigated in federal court. Further, the Supreme Court stated that the resolution of that issue in federal court was essential to the judgment on the merits and, therefore, issue preclusion barred the plaintiff's claim in Superior Court. The Supreme Court also held that the plaintiff's claim that the defendants interfered with her contract with an educational institution was not actionable. Next, the Supreme Court examined the antidiscrimination clause contained in section 2 of article 1 of the Rhode Island Constitution and held that it was not self executing. Further, the Supreme Court held that principles of judicial restraint prevented the Court from creating a private right of action under these circumstances. Accordingly, the Supreme Court affirmed the judgment of the Superior Court.