Jared Starnino v. Employees' Retirement System of the City of Providence

Summary

The Rhode Island Supreme Court reviews the Providence Employees’ Retirement System Board’s denial of Jared Starnino’s application for accidental disability retirement benefits. The Court holds that legally competent evidence, including an independent medical examiner’s opinion that Starnino could return to full-duty firefighting, supported the Board’s decision and affirms. A dissent would have concluded that the medical evidence established Starnino’s inability to perform his firefighting duties.

Holdings

1. The Board's denial was supported by legally competent evidence because Dr. Lifrak's opinion that Starnino could return to full-duty work constituted some evidence supporting the Board's conclusion that he was not incapacitated for duty.
2. The Board may find one independent medical examiner more persuasive than other physicians, including the treating physician, so long as its decision reflects a reasoned analysis of the evidence.
3. Under Providence Code of Ordinances § 17-189(f), once an employee establishes that the ordinance's accidental-disability retirement criteria are satisfied, the Board must retire the employee and lacks discretion to deny the application.

Questions Presented

1. Whether legally competent evidence supported the Retirement Board's denial of Starnino's application for accidental disability retirement.
2. Whether the Board was entitled to rely on one independent medical examiner's opinion and discount contrary medical evidence and a functional capacity evaluation.

Disposition

affirmed