No specific laws identified for this ruling.
In 2012, the defendant City of Providence passed an ordinance suspending the annual cost-of-living adjustments (COLAs) to the pension benefits for retired members of the Providence police and fire departments (the 2012 Pension Ordinance) the suspension would be in place until the then-underfunded pension fund achieved a 70 percent funding level. The City's consultants projected that the pension fund could reach a 70 percent funding level in 2036. Retiree groups and union groups initiated litigation to bar enforcement of the new ordinance. After engaging in court-ordered mediation, most retirees agreed to a settlement which allowed for a ten-year suspension of their COLA benefit. Several dozen plaintiffs 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 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 proven their claims, and entered judgment in favor of the City on all counts of the plaintiffs' complaint. The plaintiffs appealed from the final judgment, arguing that the trial justice erred by finding in favor of the City on their Contract Clause claim and by granting summary judgment prior to trial in favor of the City on their claims for violation of the Takings Clause and for promissory estoppel. The plaintiffs also argued that some of them were absolutely immunized from any changes to their COLAs because of prior judicial adjudications. The Supreme Court reversed the judgment with respect to each plaintiff who had also been a plaintiff in prior litigation regarding their COLA benefits which had ended with either a consent judgment or an individual settlem
This summary was generated to explain the ruling in plain English and is not legal advice.
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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