No specific laws identified for this ruling.
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violated the parties' collective bargaining agreement (CBA), and ordered URI to pay Jolicoeur $6,500 in salary for the rescinded "Special Programs Contract" and to cease and desist from unilaterally imposing a two-course limit.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
The Dispute
Kenneth Jolicoeur was a part-time professor at the University of Rhode Island who was initially assigned to teach two courses plus handle a "Special Programs Contract" for fall 2013. However, the university then told him he couldn't do all three assignments and would have to choose. Jolicoeur decided to teach the two classes but lost income from the special program work. His union filed a complaint, arguing the university violated their contract by limiting his work assignments.
The Court's Decision
The Rhode Island Supreme Court sided with the professor on the main issue, upholding an arbitrator's award of $6,500 in lost wages. The court agreed that the university had violated the union contract when it restricted Jolicoeur's assignments. However, the court rejected the arbitrator's order that would have prevented the university from making similar decisions in the future, ruling that this went beyond the arbitrator's authority.
Why This Matters for Workers
This case shows that union contracts can provide real protection when employers try to reduce work assignments without proper justification. Part-time workers, who often face unpredictable schedules and income, can successfully challenge unfair limitations through their union's grievance process and potentially recover lost wages.
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