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The Rhode Island Supreme Court affirmed the arbitration award of $6,500 in salary damages to the union member but vacated the arbitrator's cease-and-desist order, finding the dispute arbitrable and the CBA violation substantiated but the injunctive relief exceeded the arbitrator's authority.
Kenneth Jolicoeur, a part-time faculty member at the University of Rhode Island (URI) and a member of the American Association of University Professors, Part-Time Faculty United union (the union), was assigned two courses and a "Special Programs Contract" for the fall 2013 semester. URI then informed Jolicoeur that he could not perform all three assignments. Jolicoeur opted to teach the two classes and filed a grievance with URI protesting the limitation on assignments, but a resolution could not be reached through the grievance process. The union then filed a demand for arbitration on Jolicoeur's behalf. The arbitrator deemed the dispute arbitrable, found that URI's limitation on Jolicoeur's assignments violated the parties' collective bargaining agreement (CBA), and ordered URI to pay Jolicoeur $6,500 in salary for the rescinded "Special Programs Contract" and to cease and desist from unilaterally imposing a two-course limit. URI moved in the Superior Court to vacate the arbitration award and to stay the implementation of the award, to which the union objected and moved to confirm the award. The hearing justice denied URI's motion to vacate the arbitration award and granted the union's motion to confirm the award. On appeal to the Supreme Court, URI challenged the hearing justice's decision on three grounds: (1) the dispute was not substantively arbitrable (2) URI's imposition of a limitation did not violate the CBA and (3) the arbitrator exceeded his authority by issuing a cease-and-desist order. The Supreme Court held that: (1) the dispute was arbitrable because its resolution required interpretation of the CBA (2) the arbitrator's conclusion that URI violated the CBA was based on a passably plausible interpretation of the CBA and (3) the arbitrator exceeded his authority by imposing the cease-and-desist order. Accordingly, the Supreme Court vacated the cease-and-desist order and affirmed the judgment of the Superior Court in all other respects. Justice Indeglia
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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