Pamela Azar v. Town of Lincoln

Citations

• 173 A.3d 862

Syllabus

The plaintiff, Pamela Azar, appealed the grant of a motion for judgment as a matter of law in favor of the defendants, the Town of Lincoln, the Lincoln School Committee, and John Ward, in his official capacity as finance director for the Town of Lincoln, on her hostile work environment and retaliation claims. On appeal, the plaintiff argued that the trial justice erred in granting the motion because the plaintiff had presented sufficient evidence for a reasonable jury to find both a hostile work environment and that the defendants had retaliated against her in response to her advocacy for her disabled son's education. The Supreme Court held that the plaintiff's hostile work environment claims pursuant to the Rhode Island Civil Rights Act (RICRA), G.L. 1956 chapter 112 of title 42, and the Civil Rights of People with Disabilities Act (CRPDA), G.L. 1956 chapter 87 of title 42, were barred by the statute of limitations because the events to which the plaintiff testified occurred more than three years prior to the filing of the complaint. The Court also held that the plaintiff's retaliation claim pursuant to the CRPDA was barred because she failed to exhaust her administrative remedies. Finally, the Court concluded that her retaliation claim pursuant to the RICRA failed as a matter of law because the plaintiff did not provide sufficient evidence such that a reasonable jury could find that the defendants' actions were in retaliation for the plaintiff's advocacy for her son. As such, the Supreme Court affirmed the Superior Court's judgment.