Felkner v. Rhode Island CollegeAnnotate this Case
In this complaint brought against Rhode Island College and various college officials alleging that Defendants’ conduct toward Plaintiff during his enrollment in the Master of Social Work program due to his political beliefs violated his constitutional rights the Supreme Court vacated in part and affirmed in part the judgment of the hearing justice granting summary judgment in favor of Defendants and dismissing Plaintiff’s claim for punitive damages, holding that summary judgment must be vacated as to certain counts.
Specifically, the hearing justice held that Defendants were entitled to summary judgment on Plaintiff’s claims that Defendant violated his constitutional rights to freedom of expression and equal protection, conspired to violate his civil rights, and violated his procedural due process rights. The hearing justice also found that Plaintiff had not established a prima facie case for punitive damages. The Supreme Court held (1) summary judgment was improper as to Plaintiff’s freedom of speech claims; (2) summary judgment was proper as to Plaintiff’s equal protection and procedural due process claims; (3) Defendants were entitled to judgment as a matter of law on Plaintiff’s conspiracy claim; and (4) the hearing justice properly found that Plaintiff had not met his burden to demonstrate a prima facie case for punitive damages.