242 A.3d 32
R.I.2020Background
- Barnes worked for RIPTA as a bus driver (2002–2016) and filed numerous work-related claims against RIPTA over many years.
- In April 2018 Barnes and RIPTA executed a settlement and general release resolving claims in federal and state actions; RIPTA paid $150,000.
- Four months later Barnes filed a new 245‑page Superior Court complaint seeking $2.5 million and alleging unpaid workers’‑compensation benefits, misrepresentations, discrimination, and a reclassification claim; the complaint was vague and included many exhibits.
- RIPTA moved to dismiss under Rules 12(b)(1), (b)(3), and (b)(6), arguing the claims were either workers’‑compensation matters or barred by the settlement release and that the pleading failed to state or fairly notify claims.
- After a hearing the trial justice concluded the complaint failed to articulate cognizable Superior Court claims, found the work‑injury claims belong in Workers’ Compensation Court, granted leave to amend limited to non‑workers’‑compensation claims, and dismissed the action with prejudice when Barnes did not timely amend.
- Barnes appealed pro se; the Supreme Court affirmed, finding waiver for failure to brief issues and that dismissal was proper for lack of jurisdiction over workers’‑compensation claims, inadequate pleading, and preclusion by the settlement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Superior Court has subject‑matter jurisdiction over Barnes’s work‑injury claims | Barnes contends she is owed workers’‑comp benefits and may pursue them in Superior Court | RIPTA: workers’‑comp claims fall exclusively within Workers’ Compensation Court jurisdiction | Held: No jurisdiction in Superior Court; workers’‑comp claims belong in Workers’ Compensation Court (dismissed) |
| Whether the April 2018 settlement/release permits Barnes’s new claims | Barnes asserts settlement did not cover work‑related injuries/unemployment | RIPTA: the general release bars claims arising before signing, precluding the new suit | Held: Settlement/release precludes the non‑workers’‑comp claims Barnes attempted to raise |
| Whether the complaint satisfied Rule 8 and gave fair notice of claims | Barnes filed a voluminous pleading but did not clearly articulate federal or state claims | RIPTA: complaint fails to state short, plain claims and does not give fair notice | Held: Complaint failed Rule 8; did not adequately state Title VI, breach, or reclassification claims; dismissal proper |
| Whether Barnes stated actionable federal civil‑rights or ADA claims | Barnes referenced § 1983 and ADA and sought accommodation/compensation | RIPTA: no properly pled statutory basis or private right of action shown | Held: Barnes failed to articulate cognizable § 1983, Title VI, or ADA claims; no private right of action shown; claims waived on appeal for lack of briefing |
Key Cases Cited
- Narragansett Electric Company v. Minardi, 21 A.3d 274 (R.I. 2011) (standard and scope of review on Rule 12(b) dismissal)
- Boyer v. Bedrosian, 57 A.3d 259 (R.I. 2012) (Rule 12(b)(1) jurisdictional motions may consider evidence outside pleadings)
- Long v. Dell, Inc., 984 A.2d 1074 (R.I. 2009) (de novo review of subject‑matter jurisdiction)
- Hyatt v. Village House Convalescent Home, Inc., 880 A.2d 821 (R.I. 2005) (pleading must give opposing party fair and adequate notice)
- Tondreault v. Tondreault, 966 A.2d 654 (R.I. 2009) (issues not meaningfully developed on appeal are waived)
- Broccoli v. Manning, 208 A.3d 1146 (R.I. 2019) (application of the raise‑or‑waive rule for appellate review)