Michael J. Beagan v. Rhode Island Department of Labor and Training, Board of Review, 19-11

In 2013 Beagan was fired after posting disparaging Facebook comments; DLT denied unemployment benefits as disqualifying misconduct.
Beagan appealed unsuccessfully to the DLT appeal tribunal and the District Court, then prevailed in the Rhode Island Supreme Court (Beagan v. DLT), which reversed and ordered benefits.
After remand the District Court entered judgment consistent with the Supreme Court opinion; the Supreme Court separately awarded $25,000 to Beagan’s counsel for work before that court.
Beagan sought additional counsel fees under G.L. 28-44-57 for work performed in the unsuccessful District Court appeal; DLT opposed, arguing § 28-44-57(c)(2)(iii) requires that the claimant be awarded benefits by that specific court to recover fees for its proceedings.
The District Court denied fees; Beagan petitioned the Supreme Court to decide whether subsection (c)(2)(iii) permits recovery for lower-court work when the claimant ultimately obtains benefits on appeal.
The Supreme Court held that ‘appeal’ in § 28-44-57(c)(2)(iii) covers the judicial appellate process as a whole, allowed Beagan to seek District Court fees post-final disposition, quashed the lower-court order, and remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 28-44-57(c)(2)(iii) allows recovery of fees for a claimant’s unsuccessful District Court proceedings when the claimant later obtains benefits on further appellate review	Beagan: fees for District Court work are recoverable because a judgment in his favor ultimately entered and the award resulted from the overall appeal	DLT: statute permits fees only for the proceeding at which claimant is awarded benefits; fees must be awarded per proceeding; ministerial entry after Supreme Court order is not a District Court success	Court: “appeal” covers lower-court proceedings on the path to obtaining benefits; claimant may seek fees for those proceedings; quashed and remanded to determine reasonableness of fees
Whether separate fee petitions and an hourly rate above the District Court’s $175 cap were permissible	Beagan sought permission to exceed the $175 rate and filed supplemental petitions	DLT argued fees should be limited to the court’s $175 rate and that ministerial entries do not generate fees	Court did not decide the proper hourly rate; held fee petitions should generally be filed upon final disposition (single petition), but made an exception allowing Beagan to apply in District Court now due to prior uncertainty

Beagan v. Rhode Island Department of Labor and Training, 162 A.3d 619 (R.I. 2017) (prior Supreme Court decision reversing denial of benefits).
Park v. Ford Motor Company, 844 A.2d 687 (R.I. 2004) (statutory-interpretation reviewed de novo).
Powers v. Warwick Public Schools, 204 A.3d 1078 (R.I. 2019) (statutory-construction principles and legislative intent).
Whittemore v. Thompson, 139 A.3d 530 (R.I. 2016) (plain meaning rule for clear statutes).
Ryan v. City of Providence, 11 A.3d 68 (R.I. 2011) (interpret statute in context of whole statutory scheme).
In re Tavares, 885 A.2d 139 (R.I. 2005) (remedial statutes construed liberally).
Chambers v. Ormiston, 935 A.2d 956 (R.I. 2007) (judicial role limited to ascertaining legislative intent, not making policy).
County of Los Angeles v. Cabrales, 496 U.S. 924 (U.S. 1990) (procedural approach to fee petitions; example of denying fees without prejudice to renewal in lower court).
Cabrales v. County of Los Angeles, 935 F.2d 1050 (9th Cir. 1991) (discussion of procedural history concerning fee petitions).