Clifton Peasley v. City of Providence, by and through its Treasurer, Shomari Husband

Summary

The Rhode Island Supreme Court affirmed dismissal of Clifton Peasley’s declaratory-judgment action seeking back pay for an unpaid suspension. The Court held that the election-of-remedies doctrine barred the action because Peasley had pursued the same dispute through the grievance and arbitration process under a collective bargaining agreement. The Court also rejected his arguments that the Teachers’ Tenure Act and Uniform Declaratory Judgments Act permitted simultaneous pursuit of judicial and arbitral remedies.

Holdings

1. The election-of-remedies doctrine barred Peasley from pursuing the same back-pay dispute in the Superior Court after electing to pursue the grievance and arbitration process under the collective bargaining agreement.
2. The Teachers' Tenure Act did not create an absolute exception allowing Peasley to pursue both statutory declaratory relief and contractual arbitration for the same back-pay dispute.
3. The Uniform Declaratory Judgments Act did not permit Peasley to pursue a declaratory action simultaneously with arbitration of the same dispute.

Questions Presented

1. Whether the election-of-remedies doctrine barred Peasley from pursuing a declaratory-judgment action concerning back pay while his related grievance was pending in arbitration.
2. Whether the Teachers' Tenure Act or the Uniform Declaratory Judgments Act permitted Peasley to pursue the statutory declaratory remedy simultaneously with the contractual arbitration remedy.
3. Whether Peasley could avoid the election-of-remedies doctrine by analogizing the Teachers' Tenure Act to the antidiscrimination statutes discussed in Weeks v. 735 Putnam Pike Operations, LLC.

Disposition

affirmed