Augustina Mokwenyei v. Rhode Island Hospital

Excerpt

The plaintiff appealed from the dismissal of her complaint against her former employer, the defendant, Rhode Island Hospital. The plaintiff claimed that the defendant's termination of her employment was in violation of the Rhode Island Civil Rights Act, G.L. 1956 chapter 112 of title 42 (RICRA), and the Fair Employment Practices Act, G.L. 1956 chapter 5 of title 28 (FEPA). The Rhode Island Commission for Human Rights (the commission) was allowed to intervene pursuant to Rule 24 of the Superior Court Rules of Civil Procedure. A hearing justice of the Superior Court granted the defendant's and the commission's motions to dismiss the complaint pursuant to Rule 12(b)(6) because the plaintiff had not initiated her RICRA claim before the statute of limitations expired and because the plaintiff had not timely requested the required right-to-sue letter from the commission for her FEPA claim. On appeal, the plaintiff argued that the dismissal of her FEPA claim was in error because she had timely requested the letter from the commission, and, ultimately, the commission issued the right-to-sue letter. The Supreme Court held that, because the hearing justice considered documents outside the four corners of the complaint when she decided to dismiss the claims, the hearing justice erred by not converting the motions to dismiss into motions for summary judgment pursuant to the mandate contained in Rule 12(b). The Supreme Court also held that, even though the plaintiff had not submitted the commission's preferred form for requesting the right-to-sue letter, there was no dispute that the plaintiff complied with the formal requirements—set forth in § 28-5-24.1 and Rule 17 of the commission's Rules and Regulations—for commencing a FEPA violation action in Superior Court. Accordingly, the Supreme Court vacated the Superior Court's judgment and remanded the case for further proceedings.