Manuel Andrews, Jr. v. James Lombardi, in his capacity as Treasurer of the City of Providence, Rhode Island
Case Details
- Status — whether other courts must follow this ruling
- Published
- Procedural Posture — the stage the case had reached
- summary judgment
Related Laws
No specific laws identified for this ruling.
Claim Types
Excerpt
In 2011, the defendant City of Providence passed an ordinance that would terminate City-paid health care benefits for retirees from the Providence police department and fire department who were eligible for federal Medicare benefits (the 2011 Medicare Ordinance). A group of retirees and two unions initiated litigation to bar enforcement of the new ordinance. After engaging in court-ordered mediation, most retirees agreed to a settlement in which the retirees would enroll in Medicare upon achieving the age of eligibility and the City would pay for certain costs associated with Medicare coverage, including penalties incurred from late enrollment in various Medicare supplemental programs such as Parts B and D. Several dozen retirees opted out of the settlement agreement, however, and instead pursued their civil claims through the litigation process. The opt-out plaintiffs' claims for violation of the Takings Clause and for promissory estoppel were dismissed on the City's motion for summary judgment. The plaintiffs' claims for breach of contract and violation of the Contract Clauses of the United States and Rhode Island Constitutions went to trial. After a lengthy bench trial, the trial justice ultimately concluded that the plaintiffs had not proved their claims, and entered judgment in favor of the City on all counts of plaintiffs' complaints. The plaintiffs appealed from the final judgment, arguing that the trial justice erred by dismissing their claim for breach of contract, dismissing their claim for violation of the Contract Clauses of the Rhode Island and United States Constitutions, granting summary judgment in favor of the City on their claim that the 2011 Medicare Ordinance violated the Takings Clauses of the Rhode Island and United States Constitutions, and granting the City's motion for summary judgment regarding their claim for promissory estoppel. The Supreme Court affirmed the judgment with respect to the claims for breach of contract, violation of the Tak
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More Rulings in This Case
Other orders and opinions in Manuel Andrews, Jr. v. James Lombardi, in his capacity as Treasurer of the City of Providence, Rhode Island from the same court.
Similar Rulings
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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