No specific laws identified for this ruling.
Rhode Island Supreme Court reversed the Workers' Compensation Court's award of counsel fees and costs, finding no statutory authority to award attorneys' fees in accidental disability retirement cases.
The respondent, Municipal Employees' Retirement System of Rhode Island, sought review of a decree of the Appellate Division of the Workers' Compensation Court, awarding counsel fees and costs to the petitioner. The respondent claimed that the Workers' Compensation Court lacked specific statutory authority to award counsel fees in accidental disability retirement cases and that, if there were statutory authority to award fees, the petitioner did not submit an affidavit from a disinterested attorney to support the fee determination. The Supreme Court determined that there was nothing in the language contained in G.L. 1956 § 45-21.2-9 or in reference to G.L. 1956 § 28-35-20 that conferred to the Workers' Compensation Court statutory authority to award attorneys' fees in accidental disability retirement appeals. Accordingly, the Supreme Court quashed the decree of the Appellate Division of the Workers' Compensation Court.
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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