Glen Hebert v. The City of Woonsocket, by and through its Mayor, Lisa Baldelli-Hunt

Syllabus

The defendants, the City of Woonsocket and the Woonsocket Budget Commission (the WBC), appealed a decision and judgment of the Superior Court that granted a preliminary injunction in favor of the plaintiffs, a group of retired Woonsocket police officers. Through prior collective bargaining agreements, the City and the Woonsocket police union negotiated for the City to pay for the entire cost of health care insurance for its police officers and their beneficiaries for life upon their retirement. Soon thereafter, however, the City spiraled into a fiscal disaster and sought the appointment of a budget commission under G.L. 1956 chapter 9 of title 45 to recover from its financial distress. After the WBC was appointed, the WBC took numerous measures to alleviate the financial burdens on the City. At issue in this case, the WBC adopted a resolution that required retired police officers of the City, which included the plaintiffs, to contribute to their health insurance costs. The plaintiffs filed suit against the City and the WBC, and the Superior Court, in effect, permanently enjoined the defendants from enforcing the resolution. The defendants appealed, and argued that the trial justice erred by finding the following: (1) that the plaintiffs had a vested contractual right to free lifetime health benefits for themselves and their beneficiaries (2) that the WBC was not empowered with the statutory authority to make changes to the plaintiffs' health care benefits (3) that the WBC violated the Contract Clause of the Rhode Island Constitution when it required the plaintiffs to pay for their health insurance under a new uniform health care plan applicable to all retirees and employees and (4) that the plaintiffs established that they suffered irreparable harm. The Supreme Court agreed with the trial justice that the plaintiffs had a vested contractual right to free lifetime health benefits for themselves and their beneficiaries. However, the Court held that the WBC had the sta