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Milrad v. Hasbro, Inc.

Citations: 620 A.2d 1247; 1993 R.I. LEXIS 55; 1993 WL 43806Docket: No. 92-205-M.P.

Court: Supreme Court of Rhode Island; February 18, 1993; Rhode Island; State Supreme Court

Narrative Opinion Summary

The case involves appeals by a party against adverse judgments from the Workers’ Compensation Court concerning disputes with an employer and another entity. The primary legal issue revolves around the ripeness of the case for judicial review, as the appellate division had not issued a final decree, which is a prerequisite for judicial intervention. The court confirmed that, according to G.L.1956 (1986 Reenactment) chapter 35 of title 28, the appellate division possesses the authority to affirm, reverse, or remand trial court decisions, and a decree from this division is essential for the court to exercise its review authority. The appellate division remanded the case for additional findings on medical evidence, leading to the denial of certiorari due to the absence of a conclusive decree. Consequently, the petition for certiorari was denied, the writ was quashed, and the appellate division's order was affirmed, with the case remanded to the Workers’ Compensation Court for further proceedings. The court's decision underscores the procedural requirement that a final decree must exist for a higher court to engage in review, reflecting the hierarchical judicial processes in workers' compensation disputes.

Legal Issues Addressed

Jurisdiction of Workers’ Compensation Appellate Division

Application: The appellate division has the authority to affirm, reverse, or remand trial court decrees and its decree is necessary for further judicial review.

Reasoning: Jurisdiction is established under G.L.1956 (1986 Reenactment) chapter 35 of title 28, which allows the appellate division to affirm, reverse, or remand trial court decrees.

Petition for Certiorari

Application: Milrad's petition for certiorari was denied due to the absence of a final decree from the appellate division.

Reasoning: Since no final decree from the appellate division exists for this court to review, the petition for certiorari is denied, the previously issued writ is quashed, and the appellate division's order is affirmed.

Remand for Additional Findings

Application: The appellate division remanded the case to the trial court for additional findings related to medical evidence.

Reasoning: The appellate division remanded Milrad’s case to the trial court for additional findings related to medical evidence supporting the trial judge's disability opinion.

Ripeness for Judicial Review

Application: The court determined that it could not review the case as the appellate division had not yet issued a final decree.

Reasoning: The court agrees with Hasbro, stating that the appellate division's order must precede judicial review.