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The Rhode Island Supreme Court affirmed that the Workers' Compensation Court had subject-matter jurisdiction over the firefighter's appeal of denial of accidental disability benefits, but quashed the lower court's ruling that § 45-19.1-1 creates a conclusive presumption that firefighter cancers are work-related.
The respondent, Municipal Employees' Retirement System of Rhode Island, sought review of a decision of the Appellate Division of the Workers' Compensation Court denying its appeal and affirming the trial judge's ruling that the Workers' Compensation Court had subject-matter jurisdiction to hear the petitioner's claim and that G.L. 1956 § 45-19.1-1 created a conclusive presumption that all cancer in firefighters arises out of and in the course of their employment as firefighters. The respondent claimed that the Workers' Compensation Court did not have jurisdiction over the petitioner's case, and that the court erred in finding that G.L. 1956 chapter 19.1 of title 45 contains a conclusive presumption that all cancers in firefighters are occupational cancers. The Supreme Court held that the Workers' Compensation Court did have jurisdiction to hear the petitioner's claim, pursuant to G.L. 1956 § 45-21.2-9(f), and that chapter 19.1 of title 45 did not contain a conclusive, or any, presumption that all cancers in firefighters are occupational cancers. Accordingly, the Supreme Court affirmed the decree on review in regard to the finding that the Workers' Compensation Court had jurisdiction to hear the petitioner's claim, but quashed the decree in regard to the finding that chapter 19.1 of title 45 contains a conclusive presumption that all cancers in firefighters are occupational cancers.
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The plaintiff, Clifton Peasley (plaintiff or Peasley), appealed the Superior Court's dismissal of his action for declaratory relief, which sought, inter alia, a decree that he was entitled to back pay. The Supreme Court affirmed the dismissal pursuant to the election of remedies doctrine. In this respect, it was undisputed that before commencing the action for declaratory relief, the plaintiff had filed a grievance seeking back pay, which proceeding remained pending in arbitration. Peasley's efforts to compare the provisions of the Teachers' Tenure Act with the landmark antidiscrimination protections discussed in Weeks v. 735 Putnam Pike Operations, LLC, 85 A.3d 1147 (R.I. 2014), was unavailing. The judgment of the Superior Court was affirmed.
The plaintiff, Jane Doe, appealed from a Superior Court judgment dismissing her complaint against the defendants, Brown University and two of its employees. In Superior Court, the plaintiff asserted claims under both the Rhode Island Civil Rights Act (RICRA) and article 1, section 2 of the Rhode Island Constitution. On appeal, the plaintiff argued that the hearing justice erred in determining that her claims under RICRA were precluded by the prior dismissal of the plaintiff's federal Title IX claim. The plaintiff also argued that the hearing justice erred in holding that section 2 of article 1 of the Rhode Island Constitution does not grant the plaintiff a private right of action. The Supreme Court first held that the plaintiff's claims under RICRA were predicated upon the defendants' alleged violations of Title IX, which had already been litigated in federal court. Further, the Supreme Court stated that the resolution of that issue in federal court was essential to the judgment on the merits and, therefore, issue preclusion barred the plaintiff's claim in Superior Court. The Supreme Court also held that the plaintiff's claim that the defendants interfered with her contract with an educational institution was not actionable. Next, the Supreme Court examined the antidiscrimination clause contained in section 2 of article 1 of the Rhode Island Constitution and held that it was not self executing. Further, the Supreme Court held that principles of judicial restraint prevented the Court from creating a private right of action under these circumstances. Accordingly, the Supreme Court affirmed the judgment of the Superior Court.
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