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Rhode Island Supreme Court Rules in Favor of Trooper’s Disability Pension

Courtroom where the Rhode Island Supreme Court ruled on a disability pension case.

News Summary

The Rhode Island Supreme Court has ruled in favor of former Trooper Staci Shepherd, affirming her right to a disability pension after a heart attack during training. The court overturned a previous denial by the State Police superintendent, establishing that employment conditions contributed to her medical condition. This significant ruling emphasizes the need for proper evaluation of the relationship between job conditions and health issues for first responders.

Providence, Rhode Island – The Rhode Island Supreme Court has ruled in favor of former Trooper Staci Shepherd, affirming her right to a disability pension following a heart attack she suffered during a training exercise. In a closely contested 3-2 decision, the court overturned a previous denial from the State Police superintendent, concluding that there was a causal relationship between Shepherd’s employment conditions and her heart attack.

Shepherd, a veteran of the Rhode Island State Police with 22 years of service, experienced her heart attack on May 2, 2017, while participating in a firearms requalification program. After the incident, her physician determined that she could not return to full duty without restrictions. However, her application for a disability pension was initially denied by then-State Police Superintendent Col. James M. Manni, who claimed that Shepherd did not sufficiently prove her heart attack was “causally related” to her employment.

In its ruling, the Supreme Court emphasized the necessity of demonstrating that work conditions could contribute to health issues, rather than requiring proof that they were the sole cause. The court referenced the 1985 Mulcahey v. New England Newspapers, Inc. decision to support its findings, indicating that Manni had applied the wrong standard in evaluating Shepherd’s case. Justice Maureen McKenna Goldberg noted that in cases of heart attacks, it is sufficient if employment conditions “contribute” to the injury.

Shepherd’s attorney highlighted the significant stress and demanding hours associated with her role at the State Police, which were acknowledged as contributing factors to her heart attack. The court’s decision pointed out that the State Police’s own expert had previously warned that returning Shepherd to work could pose a risk of further heart attacks or even death.

According to the ruling, the burden is on the superintendent to assess whether a claimant’s job “played a role” in their medical condition rather than requiring absolute proof of direct causation. Prior to her heart attack, Shepherd exhibited no risk factors for cardiovascular disease, maintained a regimen of regular exercise, and was considered in excellent health.

Following her recovery, Shepherd sought a disability retirement due to the ongoing medical issues stemming from the heart attack. In May 2020, a non-adversarial hearing was conducted where her medical records were evaluated, but Manni denied her application three months later, leading to an appeal. Judge Richard D. Raspallo from Providence Superior Court subsequently ruled in favor of Shepherd, concluding that Manni had erred by asking for a higher standard of causation than necessary.

The Supreme Court’s ruling affirmed this judgment, stating that the superintendent failed to appropriately apply the correct standard regarding causation in Shepherd’s case. However, dissenting judges argued that Manni’s discretion in choosing between permissible standards was appropriate and should be granted deference.

Justice William Robinson III raised concerns that Manni’s discretion in his decision was not an abuse of power, suggesting that the choice of standards was a matter of judgment rather than a straightforward error. The ruling is especially significant given that, as of the decision date, only four out of 400 active Rhode Island State Police retirees had successfully obtained disability pensions.

This case highlights ongoing issues related to occupational health and the challenges faced by first responders in securing necessary support for injuries sustained during their service.