Introduction

State of Rhode Island, Department of Corrections v. Rhode Island State Labor Relations Board (No. 2022-285-M.P.) is a decision of the Rhode Island Supreme Court handed down on April 9, 2025. At its core, the case addresses whether the Department of Corrections (DOC) director’s unilateral revisions to the department’s Absenteeism Management Program (AMP) were mandatory subjects of collective bargaining under the Rhode Island State Labor Relations Act (the Act) or instead fell within the director’s nondelegable statutory authority under G.L. 1956 § 42-56-10. The petitioner, the Rhode Island Brotherhood of Correctional Officers (RIBCO), argued that the AMP changes materially altered working conditions and thus required pre-implementation bargaining. The DOC defended its actions as a valid exercise of management rights necessary to maintain security, safety, and order in correctional facilities. After conflicting decisions by the State Labor Relations Board (SLRB) and the Superior Court, the Supreme Court granted certiorari to resolve whether legally competent evidence supported the board’s finding of an unfair labor practice.

Summary of the Judgment

1. In July 2019, the DOC director issued an AMP Memo revising discipline tracks, sanctions for absenteeism, sick-note acceptance standards, and scrutiny of pattern sick-time abuse.

2. RIBCO demanded bargaining over these changes; the DOC refused, claiming authority under the management-rights clause of the collective bargaining agreement (CBA) and § 42-56-10.

3. The SLRB found, by a preponderance of the evidence, that all but the sick-note requirement revisions were material and substantial changes to working conditions, and that the DOC violated the Act by refusing to bargain.

4. The Superior Court reversed, concluding (a) the board’s decision lacked substantial evidence and (b) the AMP revisions fell squarely within the director’s nondelegable statutory powers under § 42-56-10(2), (5) & (7).

5. The Supreme Court affirmed the Superior Court, holding that the board’s factual findings were inconsistent and that, as a matter of law, management rights under § 42-56-10 excused the duty to bargain over these operational security measures.

Analysis

Precedents Cited

• Vose v. Rhode Island Brotherhood of Correctional Officers, 587 A.2d 913 (R.I. 1991): Recognized that a CBA cannot divest the DOC director of statutory authority under § 42-56-10; involuntary overtime rules imposed for facility security were a non-bargainable exercise of management rights.
• Town of Burrillville v. R.I. State Labor Relations Board, 921 A.2d 113 (R.I. 2007): Established standards for judicial review of administrative labor-board decisions under the Administrative Procedures Act (§ 42-35-15).
• State Department of Administration v. R.I. Council 94, A.F.S.C.M.E., 925 A.2d 939 (R.I. 2007): Held that a statutory conflict between a CBA and a state agency’s legislatively delegated authority excuses bargaining only when clear conflict exists.
• Beagan v. R.I. Dept. of Labor & Training, 162 A.3d 619 (R.I. 2017): Clarified “legally competent evidence” review standard on certiorari.

Legal Reasoning

The Supreme Court’s analysis proceeded in two parts:

1. Fact-Finding and Substantial Evidence. The Court found the SLRB’s decision internally inconsistent. The board both relied on the AMP Memo’s “current vs. new system” construct to show unilateral change yet later described identical processes as “reiteration” not change. In neglecting the DOC director’s uncontradicted testimony on security, staffing, and inmate-safety rationales, the board failed to ground its findings in reliable, probative evidence as required by the APA (§ 42-35-15(g)(5)).
2. Error of Law: Scope of § 42-56-10 Management Rights. Section 42-56-10 empowers the DOC director to “maintain security, safety, and order” (§ 42-56-10(2)), “manage, direct, and supervise” operations (§ 42-56-10(5)), and “hire…suspend…or take other necessary disciplinary action” (§ 42-56-10(7)). As in Vose, these broad statutory powers cannot be contractually bargained away. The AMP changes—discipline tracks, escalation of sanctions, and review of pattern abuse—were operational measures to safeguard facility security and staffing. Because these were valid exercises of nondelegable statutory authority, the DOC owed no duty to bargain under the Act.

Impact on Future Cases

This decision reinforces the principle that public-sector employers cannot dilute or prohibit the exercise of statutorily granted management rights through collective bargaining. It clarifies that:

• Operational and security directives anchored in statutory duties are non-bargainable.
• Labor boards must carefully weigh evidence of institutional safety and security rationales when reviewing alleged unfair labor practices.
• Collective bargaining agreements cannot supersede clear legislative mandates delegating management authority.

Going forward, unions must focus objections on direct statutory conflicts rather than asserting bargaining rights over core management prerogatives.

Complex Concepts Simplified

Nondelegable Statutory Authority

Power granted by statute that cannot be given away or restricted by contract (e.g., a director’s duty to maintain prison security).

Management-Rights Clause

A provision in a collective bargaining agreement reserving certain operational decisions to management. It does not override conflicting statutory commands.

Mandatory Subjects of Bargaining

Employment terms—such as wages, hours, and working conditions—that employers must negotiate with unions unless preempted by statute.

Administrative Procedures Act Review (§ 42-35-15)

Courts defer to agency fact-finding unless it is “clearly erroneous” or unsupported by substantial evidence; legal questions are reviewed de novo.

Conclusion

State of Rhode Island, Department of Corrections v. Rhode Island State Labor Relations Board clarifies that the Rhode Island Department of Corrections director’s broad statutory powers under § 42-56-10 to ensure institutional security and operational discipline are nondelegable and non-bargainable. The ruling underscores the judiciary’s role in deferring to legislative grants of management authority and demands rigorous evidentiary support for labor-board findings of unfair labor practices when security and safety are at stake. This precedent will shape future public-sector labor disputes by delineating the boundary between statutory management prerogatives and mandatory subjects of collective bargaining.