Community College of Rhode Island v. CCRI Educational Support Professional Association/NEARI

The plaintiff, Michael Crenshaw, appealed from a January 7, 2019 judgment entered in the Providence County Superior Court in favor of the defendants, the State of Rhode Island and Lieutenant Scott Raynes (State Defendants) and the Community College of Rhode Island, the Council on Postsecondary Education, and Captain Timothy Poulin (CCRI Defendants), pursuant to a grant of both the State Defendants' motion to dismiss based on Rule 12(b)(6) of the Superior Court Rules of Civil Procedure and the CCRI Defendants' motion for judgment on the pleadings based on Rule 12(c). The plaintiff also appealed from a December 21, 2018 order denying his motion to amend his complaint. On appeal, the plaintiff argued that the hearing justice erred in dismissing his claim under G.L. 1956 § 28-50-3 of the Rhode Island Whistleblowers' Protection Act (the Act) because, in the plaintiff's view, the statute does not limit protection to reports of the particular employer relative to which the Act's protection is sought. The plaintiff also argued that the hearing justice erred in denying his motion to amend his complaint as to the allegations supporting his claim under 42 U.S.C. § 1983 on the basis that it was barred by the statute of limitations and, therefore, futile. The Supreme Court held that the hearing justice correctly determined that the plaintiff failed to state a valid claim under the Act because the activity occurred while Mr. Crenshaw was not employed by the defendants and involved violations of law allegedly committed by a previous employer—an entity that had no nexus with CCRI. The Court also held that the hearing justice did not abuse her discretion in denying the plaintiff's motion to amend his complaint as futile because his claim under 42 U.S.C. § 1983 was barred by the statute of limitations. Accordingly, the Court affirmed the judgment and the order of the Superior Court.