No specific laws identified for this ruling.
The respondent, Employees' Retirement System of Rhode Island (ERSRI), sought review by a writ of certiorari of a Workers' Compensation Court (WCC) order denying its motion to dismiss an appeal by the petitioner, Sean M. O'Connell (Mr. O'Connell), of a state retirement board decision denying his request for an accidental disability pension. ERSRI argued, as it had before the WCC, that the WCC lacked subject matter jurisdiction to consider an appeal from a state employee's denial of benefits. This Court concluded that the WCC lacked subject matter jurisdiction to consider Mr. O'Connell's appeal because a state employee's entitlement to benefits is adjudicated pursuant to G.L. 1956 § 36-10-14, which does not contain a provision authorizing appeals to the WCC. Accordingly, the Supreme Court quashed the order of the WCC denying ERSRI's motion to dismiss and remanded the case with instructions that the WCC dismiss Mr. O'Connell's appeal.
This summary was generated to explain the ruling in plain English and is not legal advice.
The plaintiff, Clifton Peasley (plaintiff or Peasley), appealed the Superior Court's dismissal of his action for declaratory relief, which sought, inter alia, a decree that he was entitled to back pay. The Supreme Court affirmed the dismissal pursuant to the election of remedies doctrine. In this respect, it was undisputed that before commencing the action for declaratory relief, the plaintiff had filed a grievance seeking back pay, which proceeding remained pending in arbitration. Peasley's efforts to compare the provisions of the Teachers' Tenure Act with the landmark antidiscrimination protections discussed in Weeks v. 735 Putnam Pike Operations, LLC, 85 A.3d 1147 (R.I. 2014), was unavailing. The judgment of the Superior Court was affirmed.
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.
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