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Robin Brindle v. Rhode Island Department of Labor and Training, by and through its Director

RIJune 18, 2019No. 16-324, 325, 326, 328, 329
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Case Details

Judge(s)
Suttell, Goldberg, Flaherty, Robinson, Indeglia
Status — whether other courts must follow this ruling
Published
Procedural Posture — the stage the case had reached
Petition for writ of certiorari to Rhode Island Supreme Court; affirmed judgment of Superior Court

Related Laws

No specific laws identified for this ruling.

Outcome

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.

Excerpt

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.

What This Ruling Means

**The Dispute** Five Rhode Island workers filed wage complaints against Delta Airlines through the state's Department of Labor, claiming they were owed extra pay for working on Sundays and holidays under Rhode Island law. The state agency denied their claims, and the workers appealed through the court system, eventually reaching the Rhode Island Supreme Court. **The Court's Decision** The Rhode Island Supreme Court sided with Delta Airlines and upheld the denial of the workers' claims. The court ruled that Rhode Island's law requiring extra pay for Sunday and holiday work doesn't apply to airlines because federal aviation law takes priority over state wage laws in the airline industry. **What This Means for Workers** This ruling shows that airline employees may not be protected by certain state wage and hour laws that cover other workers. When federal laws govern an entire industry like aviation, they can override state worker protections. Workers in federally regulated industries like airlines, trucking, and railroads should understand that their rights may be determined more by federal law than state law. If facing wage issues, these workers may need to pursue claims under federal regulations rather than state protections that might not apply to their industry.

This summary was generated to explain the ruling in plain English and is not legal advice.

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