Family Dollar Stores of Rhode Island, Inc. v. Justin B. Araujo

CourtSupreme Court of Rhode Island
DecidedApril 14, 2022
Docket20-163
StatusPublished

This text of Family Dollar Stores of Rhode Island, Inc. v. Justin B. Araujo (Family Dollar Stores of Rhode Island, Inc. v. Justin B. Araujo) is published on Counsel Stack Legal Research, covering Supreme Court of Rhode Island primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Family Dollar Stores of Rhode Island, Inc. v. Justin B. Araujo, (R.I. 2022).

Opinion

April 14, 2022

Supreme Court

No. 2020-163-Appeal. (PC 16-1113)

(Dissent begins on Page 21)

Family Dollar Stores of Rhode : Island, Inc.

v. :

Justin B. Araujo et al. :

NOTICE: This opinion is subject to formal revision before publication in the Rhode Island Reporter. Readers are requested to notify the Opinion Analyst, Supreme Court of Rhode Island, 250 Benefit Street, Providence, Rhode Island 02903, at Telephone (401) 222-3258 or Email opinionanalyst@courts.ri.gov, of any typographical or other formal errors in order that corrections may be made before the opinion is published. Supreme Court

Present: Suttell, C.J., Goldberg, Robinson, Lynch Prata, and Long, JJ.

OPINION

Justice Robinson, for the Court. The plaintiff, Family Dollar Stores of

Rhode Island, Inc. (Family Dollar), appeals from the Providence County Superior

Court’s denial of its motion for summary judgment and the grant of summary

judgment in favor of the defendant, Justin Araujo.1 (Mr. Araujo is the defendant in

this action for declaratory judgment; he was the complainant in the case before the

1 Before Family Dollar filed the motion for summary judgment that is at issue in this appeal, an entirely separate issue was decided by this Court. Family Dollar Stores of Rhode Island, Inc. v. Araujo, 204 A.3d 1089 (R.I. 2019) (Family Dollar I). After the opinion deciding that issue was issued, the case was remanded to the Superior Court for that court to determine “the validity and enforceability of the contractual settlement agreement * * *.” Id. at 1100. It is the Superior Court’s ruling as to the latter issue which is the subject of the instant appeal.

-1- Rhode Island Commission for Human Rights, which we discuss infra.) The only

issue before this Court is whether a release agreement signed by Mr. Araujo is, as

Family Dollar contends, all-encompassing—or whether, as Mr. Araujo contends, it

is much more narrow in scope. For the reasons set forth in this opinion, we hold that

the release unambiguously constitutes a waiver by Mr. Araujo of his right to pursue

all claims that he could make against Family Dollar. Accordingly, it is our opinion

(1) that the hearing justice erred in granting summary judgment in favor of Mr.

Araujo; and (2) that the hearing justice should have granted Family Dollar’s motion

for summary judgment.

This case came before the Supreme Court pursuant to an order directing the

parties to show cause why the issues raised in this appeal should not be summarily

decided. After carefully considering the parties’ arguments (both written and oral)

and after reviewing the record, we are of the opinion that cause has not been shown

and that the appeal may be resolved without further briefing or argument. For the

reasons set forth in this opinion, we reverse the judgment of the Superior Court.

-2- I

Facts and Travel

Because this is not the first time that this Court has dealt with the litigation in

which the instant parties are involved,2 we shall focus in this opinion only on the

facts and issues that are of immediate pertinence.

A

The Evolution of the Controversy

On January 18, 2012, Mr. Araujo filed a workers’ compensation claim against

his employer (Family Dollar), alleging that he had been injured on January 17, 2012

during the course of his employment. Consequently, Mr. Araujo began to receive

weekly workers’ compensation benefits from January 18, 2012 to August 12, 2012

and then beginning again on April 4, 2013—both periods of benefits relating to the

same January 17, 2012 injury. Thereafter, on September 12, 2014, Mr. Araujo’s

attorney sent a letter to Family Dollar in which he alleged that he had been

constructively discharged from his employment with Family Dollar on February 12,

2014. In his letter, Mr. Araujo also informed Family Dollar of his intent to “file a

2 For a full recitation of the factual history and earlier procedural travel of this case, we refer the reader to our opinion in Family Dollar I. The initial paragraphs of the “Facts and Travel” section of that opinion summarize the essential occurrences that constitute the context for the issues which we are called upon to address in this appeal. Family Dollar I, 204 A.3d at 1091-93.

-3- complaint with the Rhode Island Human Rights Commission” because, as Mr.

Araujo alleged, Family Dollar had discriminated against him on the basis of an

illness completely unrelated to his workers’ compensation injury.

Thereafter on September 23, 2014, Mr. Araujo entered into a written

settlement agreement with Family Dollar and Sedgwick Claims Management

Services, Inc. (Sedgwick).3 As part and parcel of that settlement agreement, Mr.

Araujo signed a broadly worded release (the Release), which included the following

pertinent language:

“KNOW ALL MEN THAT I, JUSTIN ARAUJO, in consideration of the sum of TWENTY THOUSAND ($20,000.00) DOLLARS * * * paid by SEDGWICK CLAIMS MANAGEMENT SERVICES, INC. on behalf of FAMILY DOLLAR STORES OF RHODE ISLAND, INC., the receipt whereof is hereby acknowledged, do hereby remise, release and forever quitclaim unto the said SEDGWICK CLAIMS MANAGEMENT SERVICES, INC. and FAMILY DOLLAR STORES OF RHODE ISLAND, INC., * * * all manner of actions, debts, dues, claims and demands, both in law and in equity, and more especially any claim that I might have * * * under the provisions of an agreement or decree relative to workers’ compensation paid to me during the period of total and partial disability resulting from an injury sustained by me in the course of my employment on or about 01/17/2012, or under the provisions of the Workers’ Compensation Act * * *. This release waives any other claims I could make against my employer, its agents, assigns, or successors, including, but not limited to, claims under the Americans with Disabilities Act, claims with the Rhode Island

3 This is the “contractual settlement agreement” referred to in Family Dollar I, 204 A.3d at 1100. See footnote 1, supra. -4- Governor’s Commission on the Handicapped, Rhode Island Commission for Human Rights, Equal Employment Opportunity Commission, FETA [sic], United States Department of Labor, United States Department of Justice, Workers’ Compensation Court, or any other agencies, tribunals, commissions, or courts.”

On November 28, 2014, some two months after having executed the Release,

Mr. Araujo filed a charge of discrimination with the Rhode Island Commission for

Human Rights, alleging that Family Dollar had discriminated against him on the

basis of the above-referenced illness that was completely unrelated to his workers’

compensation injury.4 The charge of discrimination alleged that the final

discriminatory act had taken place on February 12, 2014 (i.e., several months before

Mr. Araujo signed the Release).

On March 10, 2016, Family Dollar filed a complaint in the Superior Court

seeking a declaration that the parties had “entered into a valid and enforceable

settlement agreement” which released Family Dollar from all claims that Mr. Araujo

had set forth in his charge of discrimination.5 Family Dollar also alleged that, by

4 At the time of the signing of the Release, Mr. Araujo was represented by counsel. The record indicates that Mr. Araujo was represented by a different attorney in connection with his charge of discrimination. 5 The Rhode Island Commission for Human Rights was permitted to intervene as a defendant in this case pursuant to an order issued by the Superior Court on May 31, 2016.

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