Foster-Glocester Regional School Committee v. Board of Review, Department of Labor and Training

Summary

The Rhode Island Supreme Court reviewed a decision affirming unemployment benefits awarded to a schoolteacher terminated for inappropriate conduct involving female students. The court held that the case was reviewable despite mootness, that the confirmed arbitration award had collateral-estoppel effect, and that the Board of Review abused its discretion by giving no evidentiary weight to the arbitration transcripts. The court quashed the District Court's judgment and directed that the unemployment-benefits award be vacated.

Holdings

1. The appeal was reviewable despite payment of Bailey's unemployment benefits because the evidentiary issue was of extreme public importance and capable of repetition while evading judicial review.
2. The confirmed arbitration award had collateral-estoppel effect in the unemployment-benefits proceeding because the parties or their privies had a full and fair opportunity to litigate, the award became a final judgment, and the factual issues were identical.
3. The arbitrator's finding that Bailey engaged in inappropriate physical touching and verbal communications with students established proved misconduct that, as a matter of law, constituted deliberate conduct in willful disregard of the employer's interest and barred unemployment compensation under § 28-44-18.
4. After admitting the arbitration transcript into evidence, the Board could not refuse to consider it solely because it was hearsay and lacked corroborating direct evidence; that refusal was arbitrary and capricious and an abuse of discretion.

Questions Presented

1. Whether the District Court properly deemed the school committee's challenge to the unemployment-benefits award moot after Bailey received the benefits.
2. Whether the confirmed arbitration award and its factual findings had collateral-estoppel effect in the unemployment-benefits proceeding.
3. Whether the Board of Review abused its discretion by refusing to give any evidentiary weight to the arbitration hearing transcripts after admitting them into evidence.

Disposition

quashed