City of Cranston v. International Brotherhood of Police Officers, Local 301, 115 A.3d 971

Officer Tori‑Lynn Heaton opted into the State Municipal Employees’ Retirement System (MERS) in 1995 after previously working for the City of Cranston; her CBA, an MOA, and a Cranston ordinance included a "round‑up" rule crediting any year with >6 months as a full year for pension service.
ERSRI informed the city in 2009 that MERS eligibility requires a full 20 years under state law, so Heaton could not retire at 19 years, 6 months, 1 day despite the round‑up rule.
Heaton filed a grievance asserting contractual entitlement to the round‑up credit; she nevertheless worked the full 20 years and retired before any remedial relief was provided.
An arbitrator ruled the city breached the CBA by refusing to apply the round‑up rule to MERS members, held the city remained contractually obligated to provide the benefit, and issued a declaratory award (no monetary remedy to Heaton because she completed 20 years).
The City moved in Superior Court to vacate the arbitration award, arguing the arbitrator exceeded authority by enforcing terms conflicting with state law; the Superior Court granted the motion and vacated the award.
The union appealed; the Supreme Court affirmed, holding the arbitrator exceeded his authority because the round‑up provision conflicted with state statutes and statutory allocation of authority to the retirement board.

Issue	Plaintiff's Argument (Union)	Defendant's Argument (City)	Held
Whether the arbitration award conflicted with state law	No direct conflict; statute doesn’t prohibit round‑up, so CBA/MOA/ordinance can govern	Round‑up conflicts with MERS statutes requiring full 20 years and is preempted	Held for City: round‑up conflicts with state law and statutory 20‑year requirement
Whether arbitrator exceeded authority by deciding non‑arbitrable issue	Arbitrator properly interpreted contract and MOA incorporated into CBA	Arbitrator ruled on matters reserved to state law/agency and thus exceeded authority	Held for City: arbitrator exceeded authority; award vacated
Whether the arbitrator could craft a remedy or add contract terms	Contract interpretation permitted enforcement of agreed benefits	Arbitrator effectively added terms and created obligations contrary to statute	Held for City: award illegitimate because it attempted to enforce terms contrary to law
Mootness / justiciability of the appeal	Union sought review despite retired grievant; issue capable of repetition	City did not argue mootness; Court considered public‑importance exception	Court proceeded: issue capable of repetition yet evading review, so merits considered

State (Department of Administration) v. Rhode Island Council 94, A.F.S.C.M.E., AFL‑CIO, Local 2409, 925 A.2d 939 (R.I. 2007) (arbitration awards upheld absent manifest disregard or irrational result)
Providence Teachers Union v. Providence School Board, 725 A.2d 282 (R.I. 1999) (standard for vacating arbitration awards)
State Department of Corrections v. Rhode Island Brotherhood of Correctional Officers, 64 A.3d 734 (R.I. 2013) (grounds for vacatur include non‑arbitrability)
State v. Rhode Island Alliance of Social Services Employees, Local 580, SEIU, 747 A.2d 465 (R.I. 2000) (government employers cannot bargain away statutory obligations)
Rhode Island Brotherhood of Correctional Officers v. State Department of Corrections, 707 A.2d 1229 (R.I. 1998) (arbitrability and statutory preemption limits)
Woonsocket Teachers’ Guild, Local 951, AFT v. Woonsocket School Committee, 770 A.2d 834 (R.I. 2001) (state law trumps contrary arbitration awards)
Pawtucket School Committee v. Pawtucket Teachers Alliance, 610 A.2d 1104 (R.I. 1992) (arbitration cannot override statutory allocation of remedial authority)
Chester v. aRusso, 667 A.2d 519 (R.I. 1995) (parties may contract for greater benefits but not in conflict with statute)
Torrado Architects v. Rhode Island Department of Human Services, 102 A.3d 655 (R.I. 2014) (arbitrability is a question of law reviewed de novo)