City of East Providence v. International Association of Firefighters Local 850

Summary

The Supreme Court of Rhode Island upheld an arbitration award requiring the City of East Providence to restore 44 days of sick leave to a firefighter who had taken leave for prostate cancer treatment. The court held that Rhode Island's Cancer Benefits for Fire Fighters statute provides injured-on-duty benefits to qualifying firefighters, including those employed by East Providence, regardless of participation in the optional retirement plan. The court also concluded that the arbitrator did not exceed his authority by interpreting the applicable statutes and collective-bargaining agreement.

Holdings

1. The arbitrator did not exceed his authority by interpreting and applying the Cancer Benefits for Fire Fighters statute and the injured-on-duty statute to resolve the grievance.
2. The Cancer Benefits for Fire Fighters statute applies to East Providence firefighters and provides injured-on-duty benefits for qualifying occupational cancer, regardless of whether the municipality participates in the optional retirement plan.
3. The award was not irrational and did not create impermissible nonbargained benefits because the injured-on-duty benefits were required by the collective-bargaining agreement and applicable statutes.

Questions Presented

1. Whether the arbitrator exceeded his authority by interpreting Rhode Island's Cancer Benefits for Fire Fighters statute and applying it through the collective-bargaining agreement.
2. Whether the Cancer Benefits for Fire Fighters statute applies to East Providence firefighters even though the City does not participate in the optional retirement plan for police officers and firefighters.
3. Whether the arbitration award was irrational or otherwise subject to vacatur because it imposed unfunded injured-on-duty benefits or created benefits not obtained through collective bargaining.

Disposition

affirmed