The Supreme Court of Rhode Island addressed whether retired firefighters were entitled to occupational cancer disability benefits under a state law or a city ordinance. The plaintiffs, represented by the Providence Retired Police and Firefighter’s Association, sought a declaratory judgment requiring the City to process their applications for cancer benefits under a state law, the Rhode Island Cancer Benefits for Firefighters Act, rather than under a local ordinance. The Court ruled in favor of the City, holding that the City’s ordinance, which established a separate pension system for Providence firefighters, superseded the general state law.
The Rhode Island Cancer Benefits for Firefighters Act was enacted in 1986 and provides benefits to firefighters who develop occupational cancer, defined as “cancer arising from exposure to hazardous substances during their employment.” The Act includes a conclusive presumption that any cancer found in a firefighter is occupational, entitling them to disability benefits. However, the City of Providence, Rhode Island operates under a separate pension system established by a 1923 state law, which was later incorporated into local ordinances after the City adopted a home rule charter in 1983. In 2008, the City enacted an ordinance specifically addressing cancer benefits for firefighters, which imposed stricter requirements for eligibility, including annual physical exams and a diagnosis within three years of retirement.
The plaintiffs, retired firefighters represented by the Providence Retired Police and Firefighter’s Association, sought a declaratory judgment requiring the City to process their applications for cancer benefits under the state Act, rather than under the stricter local ordinance, arguing that the Act applied to all firefighters in Rhode Island, regardless of whether their municipality participated in the state’s Municipal Employees Retirement System (MERS). They contended that the Act’s language, which refers to “any fire fighter,” included them and entitled them to the conclusive presumption of occupational cancer. The City, however, maintained that its local ordinance governed the provision of cancer benefits for Providence firefighters, as the City’s pension system was a special act that superseded the general state law.
The trial court ruled in favor of the plaintiffs, holding that the Act applied to all firefighters, including those in Providence, and that the City was required to process their applications under the Act.
The City appealed, and the Supreme Court of Rhode Island reversed the decision. The Court relied on its prior ruling in Betz v. Paolino, which held that the Providence pension system superseded general state laws, including the Act. The Court emphasized that the Providence system was a comprehensive framework for retirement benefits, and the City’s ordinance, enacted under that system, took precedence over the general provisions of the Act.
The Court rejected the plaintiffs’ reliance on City of East Providence v. International Association of Firefighters Local 850, a case in which the Court had ruled that the Act applied to firefighters in a municipality that did not participate in MERS. The Court distinguished that case, noting that it involved a collective bargaining agreement that specifically incorporated the Act, whereas no such agreement existed in this case. The Court also reiterated that Betz remained controlling precedent, and there was no indication that the legislature intended to override the special provisions of the Providence system when it amended the Act.
Providence Retired Police and Firefighter’s Association v. City of Providence, 329 A.3d 883 (R.I. 2025).