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Associated Builders & Contractors of Rhode Island, Inc. v. City of Providence

Citations: 754 A.2d 89; 2000 R.I. LEXIS 136; 2000 WL 748069Docket: No. 99-136-Appeal

Court: Supreme Court of Rhode Island; June 8, 2000; Rhode Island; State Supreme Court

Narrative Opinion Summary

In this appellate case, the plaintiffs, a group of nonunion contractors, challenged a Providence County Superior Court ruling that dismissed their lawsuit against the City of Providence as moot. The dispute emerged from an executive order by the city’s mayor mandating a Project Labor Agreement (PLA) for public construction projects, which the plaintiffs argued excluded them from bidding due to their 'open shop' status. They contended that the PLA increased construction costs by 5 to 10 percent. Initially, the trial court denied injunctive relief, and the project was awarded to union contractors. As the project concluded, the trial court dismissed the case on mootness grounds, highlighting the lack of an ongoing controversy. The plaintiffs appealed, claiming continuing adverse effects on their business. However, the appellate court affirmed the trial court's decision, ruling that the case did not meet the extreme public importance exception to the mootness doctrine, as it did not implicate significant constitutional or citizen voting rights. The court noted that the plaintiffs' ongoing challenges in other proceedings were sufficient for judicial review of the PLA's legality. Consequently, the appeal was denied, and the case was remanded to the Superior Court.

Legal Issues Addressed

Authority Under the Providence Home Rule Charter

Application: The plaintiffs argued that the executive order and PLA exceeded the mayor's authority under the Providence Home Rule Charter, impacting public bidding statutes; however, the court did not address the merits due to mootness.

Reasoning: The plaintiffs, including the Associated Builders and Contractors of Rhode Island, represent nonunion contractors and argue that the executive order and PLA contravene public bidding statutes and exceed the mayor's authority under the Providence Home Rule Charter.

Declaratory Judgment on Executive Orders

Application: The plaintiffs sought a declaratory judgment on the executive order and Project Labor Agreement, claiming adverse effects on their business, but the court found no justiciable controversy remained.

Reasoning: Although the plaintiffs pursued a declaratory judgment, the trial court ultimately dismissed the case on mootness grounds, as the project was completed and the plaintiffs had no interest in challenging the bidding process.

Mootness Doctrine in Judicial Proceedings

Application: The appellate court found that the trial court correctly dismissed the case as moot because the construction project was completed, and the plaintiffs had no ongoing interest in the bidding process.

Reasoning: The appellate court agreed with the trial justice's dismissal, concluding that the events had resolved the controversy and no continuing stake remained for the plaintiffs.

Public Importance Exception to Mootness

Application: The court determined that the case did not meet the criteria for the public importance exception to the mootness doctrine, as it did not involve significant constitutional rights or citizen voting rights.

Reasoning: The Court also determined that the case lacks the extreme public importance necessary to warrant an exception to the mootness doctrine, as it does not involve significant constitutional rights or citizen voting rights but rather the legality of an executive order.