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Rhode Island Supreme Court affirmed the Department of Labor and Training's denial of wage and hour claims against Delta Airlines, holding that Rhode Island's Sunday/holiday pay statute is preempted by the federal Airline Deregulation Act.
The petitioners, Robin Brindle, Kathleen Brown, Sandra Carter, Marcie LaPorte, and Kelvin Ramirez, filed petitions for writ of certiorari to this Court pursuant to the Administrative Procedures Act, G.L. 1956 § 42-35-16, seeking review of a Superior Court judgment affirming a decision of the Rhode Island Department of Labor and Training that denied the petitioners' wage and hour claims against Delta Airlines, Inc. The petition was granted, and, before the Supreme Court, the petitioners argued that the Superior Court erred in affirming DLT's finding that G.L. 1956 § 25-3-3 is preempted by federal law, specifically, 49 U.S.C § 41713(b)(1) of the Airline Deregulation Act (the ADA). The Supreme Court held that requiring airlines such as Delta to provide one-and-one-half-times the normal rate of pay for work on Sundays and holidays does in fact relate to the services provided by Delta, and, thus, the logical effect of § 25-3-3 on Delta's delivery of services is sufficient to bring the statute within the preemptive scope of the ADA. Specifically, the Court determined that the sworn testimony offered by Delta before the DLT demonstrated that forcing Delta to comply with the requirements of § 25-3-3 could significantly impact the services that Delta and other airlines provide on Sundays and holidays. The Court concluded that there was sufficient evidence in the record for the Superior Court to conclude that DLT's decision was supported by adequate and legally competent evidence. Accordingly, the Supreme Court affirmed the judgment of the Superior Court.
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