Arthur Quattrucci v. James Lombardi, in his capacity as Treasurer of the City of Providence, Rhode Island

Syllabus

The plaintiffs, a retired firefighter and two retired police officers, had reached settlements with the City of Providence in 2004, regarding the cost of living adjustments (COLAs) provided for in their respective collective bargaining agreements. The settlements were embodied as consent judgments in the Superior Court. Thereafter, the City enacted an ordinance that suspended the plaintiffs' COLAs, and the plaintiffs sued to enforce the consent judgments and hold the City in contempt of the same. Both the City and the plaintiffs moved for summary judgment. The hearing justice granted summary judgment for the City and denied summary judgment for the plaintiffs. The plaintiffs appealed. Before the Supreme Court, the plaintiffs argued that a consent judgment cannot \be overruled or otherwise modified by city ordinance[.]\ Thus, the plaintiffs contended, the hearing justice erred when she found that the ordinance modified the plaintiffs' rights under the consent judgments and that such finding violated separation of powers principles. The City countered that separation of powers principles would have been violated if the Superior Court had found the City in contempt because, according to the City, courts cannot restrain municipal bodies from exercising their legislative powers. The Supreme Court held that, to the extent that the ordinance purported to nullify the consent judgments, it violated separation-of-powers principles embodied in the Rhode Island constitution. The Supreme Court therefore held that the hearing justice erred in granting the City's cross-motion for summary judgment with respect to these plaintiffs and vacated the judgment of the Superior Court and remanded the case for further proceedings.