Kristin Riley v. The Narragansett Pension Board

CourtSupreme Court of Rhode Island
DecidedJune 2, 2022
Docket20-272
StatusPublished

This text of Kristin Riley v. The Narragansett Pension Board (Kristin Riley v. The Narragansett Pension Board) 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
Kristin Riley v. The Narragansett Pension Board, (R.I. 2022).

Opinion

June 2, 2022

Supreme Court

No. 2020-272-Appeal. (WC 19-445)

(Dissent begins on Page 23)

Kristin Riley et al. :

v. :

The Narragansett Pension Board. :

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., Robinson, Lynch Prata, and Long, JJ.

OPINION

Justice Robinson, for the Court. The Narragansett Pension Board (the

Board) appeals from a September 28, 2020 judgment of the Washington County

Superior Court permanently reinstating plaintiff Matthew Riley’s pension.1 The

Board contends on appeal that Code of Ordinances, Town of Narragansett, Rhode

Island, Supp. No. 13, § 58-36 (Sept. 18, 2019) (the pension revocation ordinance),2

is not unconstitutionally vague; that “this matter should be remanded to the

1 The plaintiffs are Kristin and Matthew Riley; they are husband and wife. In order to prevent any confusion, we shall refer to them by their first names. In so doing, we intend no disrespect. 2 We note that Section 58-36 contains the same language in Supplement No. 12 of the Code of Ordinances, Town of Narragansett, Rhode Island (May 9, 2018).

-1- pension board for a rehearing with the newly enacted rules and procedures;” and

that, if the issue of the award of attorneys’ fees is considered to be ripe for this

Court’s consideration, the Superior Court’s award of attorneys’ fees should be

vacated.

For the reasons set forth in this opinion, we vacate in part the judgment of

the Superior Court.3

I

Facts and Travel

According to the amended verified complaint filed on January 30, 2020 (the

amended complaint), Matthew was a police officer with the Narragansett Police

Department for twenty-eight years prior to his retirement in June of 2017. The

amended complaint further provided that, on or about October 5, 2017, Matthew

was indicted by a federal grand jury for violation of 18 U.S.C. § 1470, which

criminalizes knowingly transferring “obscene matter to another individual who has

not attained the age of 16 years, knowing that such other individual has not

3 It is important to bear in mind that the Board has appealed only the following portions of the Superior Court’s decision: (1) the ultimate determination by the trial justice that the pension revocation ordinance is unconstitutionally vague; (2) the trial justice’s failure to remand to the Board for rehearing; and (3) her decision to award attorneys’ fees to plaintiffs pursuant to the Equal Access to Justice for Small Businesses and Individuals Act, G.L. 1956 chapter 92 of title 42. The Board did not appeal with respect to any other portions of the judgment at issue, particularly the finding that the Rileys’ procedural due process rights had been violated.

-2- attained the age of 16 years * * *.” On or about March 15, 2019, he pled guilty to

that indictment.

The then-Acting Town Manager and Police Chief in the Town of

Narragansett (the Town), Sean Corrigan, sent a letter to Matthew informing him

that, at an upcoming meeting of the Board, the Town’s solicitor would “present a

request of the pension board to enact the provisions of Town Ordinance Sec. 58-36

entitled Benefits Forfeited * * *.” In due course, the Board ultimately held a

hearing on August 14, 2019 to determine whether or not to revoke Matthew’s

pension under the pension revocation ordinance. The pension revocation

ordinance provides, in pertinent part, as follows:

“Any member who, at or after retirement, is found guilty by the pension board of misfeasance or malfeasance during service with the town and who, but for retirement, would have been discharged or removed from such service therefore shall not be entitled to a retirement allowance under this section.” Section 58-36.

As discussed in more depth infra, the trial justice found that numerous procedural

due process violations occurred during that August 14, 2019 hearing. The Board

ultimately voted at the close of the hearing to revoke Matthew’s pension benefits.4

4 It is of note that, during the course of the hearing, the Rileys’ counsel made it clear that, in his opinion, Kristin was an innocent spouse and therefore was “capable of receiving [the] pension under the law.”

-3- On August 27, 2019, the Rileys filed a verified complaint (the initial

complaint) in the Superior Court. In that complaint, they sought review, pursuant

to G.L. 1956 § 36-10.1-5,5 of the decision of the Board to revoke Matthew’s

pension and to “deny Kristin’s right to all or a portion of Matthew’s pension as an

innocent spouse” (Count One). The initial complaint further included the

following counts: (1) a count alleging violation of the Rileys’ due process rights

(Count Two); (2) a count seeking a declaratory judgment to the effect that the

pension revocation ordinance required that any “misfeasance or malfeasance be in

connection with the individual’s job” and that Kristin was “entitled to all or a

portion of Matthew’s pension benefits as an innocent spouse” (Count Three); (3) a

count seeking injunctive relief (Count Four); and (4) a count seeking an award of

attorneys’ fees pursuant to the Equal Access to Justice for Small Businesses and

Individuals Act, G.L. 1956 chapter 92 of title 42 (EAJA) (Count Five). In their

initial complaint, the Rileys sought a temporary restraining order and further

sought preliminary and permanent injunctions “enjoin[ing] the defendant from

carrying forth its decision to revoke the Rileys’ pension benefits until such time

5 General Laws 1956 § 36-10.1-5 provides as follows:

“The superior court shall have jurisdiction to review any decisions, appeals, or other proceedings initiated pursuant to any municipal ordinance providing for the revocation or reduction of the pension of any municipal employee for circumstances constituting dishonorable service as defined by municipal ordinances.”

-4- that this court has an opportunity to review and decide the allegations set forth in

[the] complaint.”

A hearing with respect to the request for a preliminary injunction was held

before the trial justice on September 18, 2019. At the outset of the hearing,

plaintiffs suggested that, pursuant to Rule 65(a)(2) of the Superior Court Rules of

Civil Procedure,6 the hearing be consolidated with a trial on the merits. The trial

justice agreed with that suggestion, although she indicated that the attorneys’ fees

issue would be decided at a separate hearing, if necessary. It is also of note that at

that hearing, the Board stated that, if there were any “procedural defects” in the

proceeding before the Board, then the case should be remanded to the Board rather

than having the trial justice simply reverse the Board’s decision.

After that September 18 proceeding, on November 4, 2019, the trial justice

issued an initial bench decision, in which she granted the preliminary injunction.

She also directed both parties to provide her with supplemental memoranda

regarding the constitutionality of the pension revocation ordinance.

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