Opinion
No. 2021-301-Appeal KC 21-266
07-19-2023
UNITED PARCEL SERVICE, INC. v. Jeffrey GRIFFITHS.
Joseph K. Scully, Esq., for Plaintiff. Jeff Linares, Esq., for Defendant.
Joseph K. Scully, Esq., for Plaintiff.
Jeff Linares, Esq., for Defendant.
ORDER
This case presents a serious and increasingly common issue confronting trial courts: litigants who seek judicial intervention based on a fear of workplace violence. The defendant, Jeffrey Griffiths (defendant or Mr. Griffiths) appeals from a September 14, 2021 order of the Superior Court in favor of the plaintiff, United Parcel Service, Inc. (plaintiff or UPS). The Superior Court's order granted the plaintiff's motion for a preliminary injunction pursuant to the Rhode Island Workplace Violence Prevention Act, G.L. 1956 chapter 52 of title 28.
On appeal, defendant argues that the trial justice misinterpreted § 28-52-2(a) and abused his discretion when he ignored and misapplied his findings of fact as he analyzed the elements required for a preliminary injunction. For the reasons set forth in this order, we vacate the order of the Superior Court and remand for trial.
This appeal arises out of defendant's termination from employment with UPS. On March 22, 2021, UPS filed a verified complaint alleging that defendant trespassed on its property and seeking injunctive relief pursuant to § 28-52-2 of the Workplace Violence Prevention Act.
Following a four-day hearing, the trial justice issued a bench decision granting UPS's request for a preliminary injunction. The trial justice clearly struggled with the evidence presented during the hearing; he made several equivocal statements about the testimony and documents admitted into the record and expressed concerns with various aspects of the testimony. The trial justice ultimately found that defendant made statements that constituted a threat as described in the Rhode Island Workplace Violence Prevention Act. The trial justice acknowledged that a judicial determination pursuant to § 28-52-2(a) automatically establishes irreparable harm pursuant to § 28-52-2(b). Finally, the trial justice noted that the balance of the equities in this matter tipped almost evenly, but ultimately determined that a preliminary injunction would preserve the status quo and protect the public interest.
On September 14, 2021, the Superior Court entered an order that (1) enjoined defendant from trespassing on UPS's property; (2) prevented defendant from visiting, assaulting, molesting, or otherwise interfering with UPS's operations; and (3) forbade defendant from abusing or injuring UPS or its property for a period of three years or until UPS decided to rehire defendant. The defendant filed a timely notice of appeal.
General Laws 1956 § 9-24-7 permits a litigant to appeal a trial justice's grant of an injunction to this Court, despite its interlocutory status. Section 9-24-7.
We review a trial justice's decision to grant a preliminary injunction for an abuse of discretion. Gianfrancesco v. A.R. Bilodeau, Inc. , 112 A.3d 703, 708 (R.I. 2015). A party need only establish a prima facie case warranting injunctive relief; therefore, we confine our task to reviewing whether the trial justice considered and resolved the well-known four factors without committing an abuse of discretion. Id.
Specifically, the trial justice must consider and resolve whether the party seeking an injunction: (1) has a reasonable likelihood of success on the underlying merits of its claim; (2) will suffer irreparable harm if the court refuses to grant the injunctive relief; (3) has the balance of equities, which includes an analysis of the possible hardship to the moving party if the injunction is denied, the hardship to the opposing party if the injunction is granted, and the public interest; and (4) has demonstrated that a preliminary injunction will preserve the status quo. Gianfrancesco , 112 A.3d at 708.
We do not require trial justices to set forth comprehensive findings of fact. See School Committee of Town of North Kingstown v. Crouch , 808 A.2d 1074, 1077 (R.I. 2002) (noting the trial justice's scant, but adequate, analysis of each of the four preliminary injunction factors); see also Gianfrancesco , 112 A.3d at 711. However, injunctive relief is an extraordinary remedy. Brown v. Amaral , 460 A.2d 7, 10 (R.I. 1983). Therefore, although this Court does not require perfection, a trial justice must, at a minimum, articulate a coherent, unambiguous basis of support for the four factors.
We have examined the trial justice's equivocal statements about the testimony and evidence presented in this case. We recognize the difficulty of these cases, particularly given their high stakes and the concerns that stem from allegations of workplace violence. Nevertheless, we cannot conclude that the trial justice properly considered and resolved the preliminary injunction factors prior to granting this extraordinary remedy. Accordingly, we vacate the order of the Superior Court granting the plaintiff's motion for a preliminary injunction and remand this matter for trial.
Entered as an Order of this Court this 19th day of July, 2023.
Chief Justice Suttell did not participate.
Justice Robinson, concurring in part and dissenting in part.
I concur with the decision to remand this matter for trial. However, in view of the grave nature of the underlying issue (viz. , the plaintiff entity's expressed concern about the possibility of workplace violence), I would not vacate the order of the Superior Court granting the motion for a preliminary injunction. Instead, while acknowledging its shortcomings, I would leave in place the Superior Court's preliminary injunction until such time as a trial is held.