Comp settlement prevents worker from pursuing discrimination claim
Young v. Warwick Rollermagic Skating Center, Inc., No. 2008-111-Appeal (R.I. 06/30/09).
Ruling: The Rhode Island Supreme Court denied the manager's appeal and upheld the finding that the language of the settlement agreement was clear and constituted a waiver of her right to pursue all claims and demands against the employer. The dissent argued the terms were ambiguous.
What it means:
In Rhode Island, where a settlement agreement unambiguously states that the worker releases the employer from liability for all claims and demands in "any way growing out of any of personal injuries from any and all incidents or injuries occurring during employment," a court can find this applies to all claims, not strictly workers' compensation claims.
A skating rink manager was injured when she was struck by a car in the parking lot. She suffered a shoulder injury and was out of work for a period of time. She filed a workers' compensation claim but was later terminated. She filed a discrimination claim, alleging she was terminated because of her physical handicap. While the discrimination claim was pending, the manager settled her workers' compensation claim by signing a "release and settlement of claim" which included a clause for her resignation. Her former employer argued that her discrimination complaint should be dismissed because she resigned her employment, executed a release of all claims, and had not shown she was an individual with a disability under the law. The manager argued the release was related only to the workers' compensation case and not to her discrimination claim. She also argued the release language was ambiguous, as it did not specifically include her discrimination claim. The Supreme Court rejected her arguments, finding that the release's language was unambiguous. The court stated it was "struck by the sweeping and comprehensive nature of the language." The court dismissed the manager's appeal, affirming summary judgment to the employer.
The majority noted the release was "replete with such straightforward language as 'any' and 'all,'" and stated it was "quite unable to read the document other than as an all-encompassing release."
The dissent stated the majority overlooked the release's references to her specific workers' compensation claim in combination with words denoting "all claims and demands." The dissent noted the court had found similar language to be ambiguous in the past.
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August 31, 2009
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