Cote v. State of Rhode Island

CourtDistrict Court, D. Rhode Island
DecidedMarch 4, 2025
Docket1:24-cv-00075
StatusUnknown

This text of Cote v. State of Rhode Island (Cote v. State of Rhode Island) is published on Counsel Stack Legal Research, covering District Court, D. Rhode Island primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cote v. State of Rhode Island, (D.R.I. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF RHODE ISLAND

Nicholas R. Cote

v. Case No. 24-cv-75-PB-AKJ Opinion No. 2025 DNH 030 State of Rhode Island, et al.

MEMORANDUM AND ORDER

Nicholas Cote1 has sued the State of Rhode Island, the Chief Justice of the Rhode Island Supreme Court, the Chief Judge of the Rhode Island District Court, and the Administrators of the Rhode Island Supreme Court and District Court. He sued the individual defendants in their official capacities. He alleges in Count I that the defendants violated the self-care provision of the Family and Medical Leave Act (FMLA). He charges in Counts II and III that defendants violated the Rhode Island Fair Employment Practices Act (FEPA). In Count IV, he contends that the defendants violated Rhode Island’s Whistleblowers Protection Act (WPA). The defendants have

1 Cote is now deceased. Upon his death, the defendants filed motions to dismiss the case for failure to substitute the plaintiff. See Doc. 37; Doc. 38. In response, Cote’s estate moved to extend the time to seek substitution. See Doc. 41. Because I grant the defendants motion to dismiss the complaint on jurisdictional grounds, the issue of substitution is moot. Accordingly, I deny the defendants’ motion to dismiss for failure to substitute. See Doc. 37; Doc. 38. I also deny the plaintiff’s pending motions to extend time to substitute. See Doc. 41. filed a motion to dismiss contending that the plaintiff’s claims are barred by the Eleventh Amendment of the United States Constitution.

I. STANDARD OF REVIEW Defendants have mounted a facial challenge to the court’s subject matter jurisdiction. Accordingly, I address defendants’ motion under Federal Rule of Civil Procedure 12(b)(1). Under that standard, I assume that the

complaint’s well-pleaded allegations are true and construe those allegations in the light most favorable to the plaintiff. See Cebollero-Bertran v. P.R. Aqueduct and Sewer Auth., 4 F.4th 63, 69 (1st Cir. 2021). II. ANALYSIS

The Eleventh Amendment deprives federal courts of jurisdiction over claims against a state brought by citizens. Tennessee v. Lane, 541 U.S. 509, 517 (2004) (recognizing that Eleventh Amendment immunity protects states from suits brought by their own citizens as well those of other states and

countries). A federal court, therefore, cannot adjudicate a claim brought by a citizen against a state unless Congress has validly abrogated Eleventh Amendment immunity or the state has waived its immunity. Kentucky v. Graham, 473 U.S. 159, 169 (1985). The Eleventh Amendment also applies to claims against defendants sued in their official capacity as representatives of the state.2 Id.

The defendants have moved to dismiss Cote’s complaint on the grounds that the state is immune from federal review of his claims. Accordingly, I evaluate each of Cote’s claims against the state in its own right to determine whether the defendants are immune from suit. Finding that the Eleventh

Amendment bars all of the plaintiff’s claims, I grant the defendants’ motion to dismiss. A. FMLA Claim The FMLA entitles eligible employees to twelve annual weeks of

unpaid leave for specific reasons, including, among others, “a serious health condition that makes the employee unable to perform the functions of [his]

2 When, as here, a complaint names several state officers as defendants, I must look to the real, substantial party in interest to determine whether the defendants are immune from suit. See Lewis v. Clarke, 581 U.S. 155, 161-62 (2017); see also Pennhurst State Sch. & Hosp. v. Halderman, 465 U.S. 89, 101 (1984). In this case, the real party in interest is the State of Rhode Island because Cote names all parties in their official capacities as officers of the state and seeks his remedy from the state itself. As such, I evaluate the complaint and its constituent claims as claims brought against the state and refer to the defendants collectively as “the state.” See, e.g., Albiston v. Me. Com’r of Hum. Servs., 7 F.3d 258, 259 n.1 (1st Cir. 1993). position.”3 29 U.S.C. § 2612(a)(1). Employers4 are prohibited both from interfering with an employee’s rights under the statute and for

discriminating against an employee for opposing violations of the FMLA. Id. § 2615(a). To enforce the law, Congress created a private right of action for employees to sue their employers for violations of the statute in federal court. Id. § 2617(a)(2). Employees can bring FMLA claims either in law or equity.

Id. § 2617(a)(1)(A)-(B). Cote alleges that the Rhode Island courts interfered with his right to take leave under the self-care provision of the FMLA. See id. §§ 2612(a)(1)(D), 2615(a)(1). Cote seeks relief primarily in the form of damages. Doc. 1 at 13.

Cote’s effort to recoup damages, though, cannot overcome established Supreme Court and First Circuit precedent holding that Congress did not validly abrogate Eleventh Amendment immunity when it attempted to subject states to liability for violations of the FMLA’s self-care provision. In

Laro v. New Hampshire, 259 F.3d 1, 16 (1st Cir. 2001), the First Circuit

3 The protection of leave for employees with a “serious health condition,” 29 U.S.C. §2612(a)(1)(D), is often referred to as the “personal care,” “personal medical leave,” or “self-care” provision of the FMLA.

4 State governments do fall within the definition of “employer” under the FMLA. Congress included in its statutory definition of “employer” any “public agency.” 29 U.S.C. § 2611(4)(A)(iii). A “public agency” is further defined to include “the government of a State or political subdivision thereof[.]” Id. § 203(x) (as cross-referenced in § 2611(4)(A)(iii)). looked at whether there was an identified link between the self-care provision and a pattern of unconstitutional discrimination on the part of state

employers. Id. After reviewing the record, including legislative history and the scope of the relevant discrimination at the federal level, the First Circuit concluded that the “personal medical leave provision of the FMLA does not exhibit a sufficient congruence to the prevention of unconstitutional state

discrimination to validly abrogate the states’ Eleventh Amendment immunity.” Id. Several years later, the Supreme Court also considered the question of whether states were immune to suit under the self-care provision of the

FMLA and, in a plurality opinion, reached the same conclusion as the First Circuit. Coleman v. Ct. of Appeals of Md., 566 U.S. 30, 33 (2012). The Supreme Court made itself plain: To abrogate the States’ immunity from suits for damages under §5 [of the Fourteenth Amendment], Congress must identify a pattern of constitutional violations and tailor a remedy congruent and proportional to the documented violations. It failed to do so when it allowed employees to sue States for violations of the FMLA’s self-care provision.

Id. at 43-44.

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