Luther C. Parente v. Nelson Lefebvre, in his official capacity as Warden of the Department of Corrections

CourtSupreme Court of Rhode Island
DecidedJuly 3, 2026
Docket2024-0387-M.P.
StatusPublished

This text of Luther C. Parente v. Nelson Lefebvre, in his official capacity as Warden of the Department of Corrections (Luther C. Parente v. Nelson Lefebvre, in his official capacity as Warden of the Department of Corrections) 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.

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Luther C. Parente v. Nelson Lefebvre, in his official capacity as Warden of the Department of Corrections, (R.I. 2026).

Opinion

Supreme Court

No. 2024-387-M.P. (No. 24-1098)

(Concurrence begins on Page 13)

Luther C. Parente et al. :

v. :

Nelson Lefebvre, in his official : capacity as Warden of the Department of Corrections, 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

Nelson Lefebvre, in his official : capacity as Warden of the Department of Corrections, et al.

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

OPINION

Justice Lynch Prata, for the Court. This case comes before the Court

pursuant to an order of the United States Court of Appeals for the First Circuit that

certified the following question in accordance with Article I, Rule 6(a) of the

Supreme Court Rules of Appellate Procedure:

“Whether discrimination claims under the Rhode Island Civil Rights Act of 1990, R.I. Gen. Laws § 42-112-1 to 2, are ‘actions of tort’ under the State Tort Claims Act, R.I. Gen. Laws § 9-31-1(a)?”

For the reasons set forth herein, we answer in the affirmative—discrimination claims

under the Rhode Island Civil Rights Act (RICRA) are actions of tort under the State

Tort Claims Act (STCA).

-1- Facts and Travel

The plaintiffs, Luther C. Parente (Parente) and Eric L. Stewart (Stewart)

(collectively, plaintiffs), are incarcerated at the Adult Correctional Institutions.

Parente v. Wall, 708 F. Supp. 3d 192, 197 (D.R.I. 2023) (Parente I). Both Parente

and Stewart sustained ankle injuries prior to their incarceration, which they allege

require continued treatment.1 Id. at 197-98. On February 10, 2016, plaintiffs filed a

complaint against the Rhode Island Department of Corrections and several members

of its staff (collectively, RIDOC). The operative complaint is the Second Amended

Complaint (hereinafter, the complaint), which plaintiffs filed on June 22, 2020. The

complaint alleged, among other things, that RIDOC did not meet plaintiffs’ medical

needs and therefore failed to properly treat them for their preexisting medical

conditions.2 Parente v. Lefebvre, 122 F.4th 457, 460 (1st Cir. 2024) (Parente II).

1 Parente sustained multiple ankle injuries after jumping from a second-story window during his arrest. Parente v. Wall, 708 F. Supp. 3d 192, 197 (D.R.I. 2023). Parente was treated at Rhode Island Hospital, where he was diagnosed with a calcaneal fracture of his right foot and ankle in addition to other fractures in his left heel and ankle. Id. Parente’s hospital discharge papers “recommended crutches or a wheelchair, medication, ice, elevation of his foot, and medication for pain.” Id. Stewart sprained his ankle while playing basketball prior to his incarceration. Id. at 198. Stewart was treated at Kent Hospital; his discharge papers instructed him “not to put weight on his left foot and to keep his leg elevated, applying ice packs.” Id. 2 Specifically, Parente and Stewart alleged that RIDOC denied them use of an elevator and that they were forced to painfully traverse metal stairways multiple times per day. Parente, 708 F. Supp. 3d at 197-98. Parente and Stewart also alleged that they were each denied elevation pillows and other items necessary for the continued treatment of their respective injuries. Id.

-2- They cited several federal and state constitutional, statutory, and common law

provisions as bases for relief. Id.

The only count relevant to the question before this Court is Count II of the

complaint, a discrimination claim made pursuant to RICRA. Specifically, Count II

alleges that RIDOC

“discriminated against [p]laintiffs and deprived them of their rights under the RICRA, including their rights to the full and equal benefit of all laws and proceedings for the security of persons and property, rights to reasonable accommodations, and other protections under the RICRA, causing [p]laintiffs to suffer harm aforesaid, and have thereby deprived [p]laintiffs of rights secured under the RICRA * * *.”

In RIDOC’s answer to the complaint, it denied the allegations in Count II and

asserted immunity from liability under RICRA pursuant to the Eleventh Amendment

to the United States Constitution.

Eventually, the parties filed cross-motions for summary judgment. Parente II,

122 F.4th at 461. With respect to Count II, the United States District Court for the

District of Rhode Island denied RIDOC’s motion. Parente I, 708 F. Supp. 3d at 212.

The District Court first reasoned that genuine issues of material facts precluded

summary judgment. Id. at 207. Moving to the issue of sovereign immunity, the

District Court noted that “Rhode Island has enacted a broad waiver of sovereign

immunity statute” by way of the STCA. Id. at 211. Quoting from Laird v. Chrysler

Corp., 460 A.2d 425 (R.I. 1983), the District Court stated that the STCA “‘subjects

-3- the state and its political subdivisions to liability in all actions of tort in the same

manner as a private individual or corporation.’ The statute contains ‘sweeping

language abrogating the sovereign immunity of the state as well as all other political

subdivisions in Rhode Island.’” Id. (internal citation omitted) (quoting Laird, 460

A.2d at 427, 428).

The District Court went on to note that this Court “declared that ‘none of the

limitations or interpretations of this court provide venue or procedural restrictions

that might prevent a plaintiff from bringing an action in federal court.’” Parente I,

708 F. Supp. 3d at 211 (quoting Laird, 460 A.2d at 430). Additionally, the District

Court stated: “A damages action under the Civil Rights Act of 1968 sounds basically

in tort—the statute merely defines a new legal duty and authorizes the courts to

compensate a plaintiff for the injury caused by the defendant’s wrongful breach.” Id.

(brackets omitted) (quoting Curtis v. Loether, 415 U.S. 189, 195 (1974)). Citing to

Pellegrino v. Rhode Island Ethics Commission, 788 A.2d 1119, 1123-24 (R.I. 2002),

it stated that this Court has held that “a waiver of sovereign immunity may be

implicit and need not be express in the statute that gives rise to the cause of action.”

Id. The District Court thus turned its attention to the question of whether

discrimination actions sound in tort, stating that, if the question is answered in the

affirmative, “the intention of the General Assembly was to waive its sovereign

immunity.” Id.

-4- The District Court emphasized that the First Circuit has previously held that

claims made pursuant to RICRA “are claims for ‘injuries to the person’ and, as such,

share the statute of limitations for torts generally.” Parente I, 708 F. Supp. 3d at 211

(quoting Rathbun v.

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