Hagenberg v. Avedisian

Summary

The Supreme Court of Rhode Island held that the Warwick Board of Public Safety's determination that a disabled retired police officer was entitled to reimbursement for medical expenses arising from his service-connected illness was binding on the city. The court affirmed the judgment requiring continued payments, but did so on grounds different from the trial justice's promissory-estoppel ruling. The court did not reach the broader declaratory, injunctive, or promissory-estoppel issues and noted that the scope of statutory reimbursement for recurring injuries under Rhode Island's injured-on-duty statute remained unresolved.

Holdings

1. The Board of Public Safety's determination that Hagenberg was entitled to reimbursement for medical bills arising from his service-connected illness was binding on the city, absent a showing that the expenses were unconnected to his original disability.
2. The Court did not decide whether the recurrence provision of § 45-19-1 independently required the claimed post-retirement payments; the judgment was affirmed on the ground that the Board's determination was binding.
3. Promissory estoppel was unnecessary to resolve Hagenberg's entitlement to continued payments.

Questions Presented

1. Whether the Rhode Island Injured on Duty statute, G.L. 1956 § 45-19-1, independently entitled Hagenberg and other retired disabled police officers and firefighters to continued payment of all medical expenses arising from their career-ending injuries.
2. Whether Warwick could unilaterally terminate medical-expense payments previously authorized by the Warwick Board of Public Safety.
3. Whether Hagenberg was entitled to relief based on promissory estoppel.

Disposition

affirmed