Rhode Island Code of Regulations Title 460 - LABOR AND TRAINING BOARD OF REVIEW
Rhode Island Code of Regulations Title 460 — Labor and Training Board of Review
1. Purpose and Scope
Title 460 governs the Labor and Training Board of Review (often referred to as the “Board”) in Rhode Island.
The Board functions as an appellate body for decisions related to labor laws, unemployment insurance claims, workers’ compensation, and employment security matters.
Its role is to provide a fair, impartial review of decisions made by administrative agencies within the Department of Labor and Training.
2. Composition and Authority
The Board is composed of appointed members who serve fixed terms.
Members have expertise in labor, employment law, and administrative processes.
The Board’s authority includes:
Reviewing appeals on unemployment insurance benefit determinations
Reviewing employer protest decisions
Addressing disputes involving wage claims, discrimination, or workplace safety under labor statutes
Hearing cases related to workers’ compensation disputes in certain instances
3. Procedural Rules
Filing an Appeal:
Aggrieved parties must file a timely appeal from agency decisions, usually within a specific number of days after notice.
Notice and Hearing:
Upon appeal, the Board schedules hearings where both parties may present evidence, testimony, and legal arguments.
Representation:
Parties may represent themselves or be represented by counsel or authorized representatives.
Record and Evidence:
The Board reviews the record from the administrative agency and may accept additional evidence as necessary.
Decision:
The Board issues written decisions which may affirm, reverse, modify, or remand the original decision.
4. Standard of Review
The Board reviews factual findings for substantial evidence, giving deference to the original agency’s fact-finding.
Questions of law are reviewed de novo (fresh review).
The Board ensures that decisions comply with applicable statutes, regulations, and procedural fairness.
5. Key Legal Principles and Case Law
a. Timeliness of Appeals
Courts and the Board strictly enforce appeal deadlines.
Late appeals are generally dismissed unless exceptional circumstances exist.
Case Principle:
Timely filing of appeals is mandatory to preserve the right to review.
b. Substantial Evidence Standard
The Board upholds agency factual findings if supported by substantial evidence, even if other interpretations are possible.
Case Principle:
Findings will not be overturned merely because reasonable minds could differ.
c. Due Process Rights
The Board must provide fair hearing procedures, including notice, opportunity to be heard, and impartial decision-makers.
Case Principle:
Failure to afford due process can result in reversal or remand.
d. Scope of Review
The Board’s review is limited to the administrative record unless new evidence is justified.
It may remand cases for further fact-finding if the record is insufficient.
6. Illustrative Case Examples
Case 1: Timely Appeal Enforcement
An employee missed the 15-day deadline to appeal a denial of unemployment benefits.
The Board dismissed the appeal for lack of jurisdiction.
The court upheld the dismissal, emphasizing the importance of strict compliance with procedural timelines.
Case 2: Substantial Evidence Review
An employer contested an unemployment claim decision favoring the employee.
The Board reviewed the testimony and records and affirmed the decision based on substantial evidence of the employee’s eligibility.
The court deferred to the Board’s factual findings.
Case 3: Due Process in Hearing Procedures
A claimant argued that the Board failed to provide adequate notice of hearing, resulting in an unfair hearing.
The court found a due process violation and ordered a new hearing.
This reinforced procedural fairness as fundamental in administrative appeals.
Case 4: Remand for Additional Evidence
The Board found the administrative record incomplete regarding a workers’ compensation dispute.
It remanded the case to the lower agency for further fact-finding before issuing a final decision.
7. Summary
| Aspect | Explanation |
|---|---|
| Purpose | Appellate review of labor and unemployment agency decisions. |
| Authority | Hear appeals, conduct hearings, issue decisions. |
| Appeal Process | Requires timely filing, notice, hearings, representation, and evidence review. |
| Standard of Review | Substantial evidence for facts; de novo for legal questions. |
| Due Process | Fair hearings and impartial decisions required. |
| Judicial Deference | Courts generally defer to Board’s factual findings and procedural rulings unless arbitrary or unfair. |
8. Conclusion
Rhode Island Code Title 460 establishes the procedural and substantive framework for the Labor and Training Board of Review to function as an impartial appellate body. It plays a critical role in ensuring that labor and unemployment decisions are justly reviewed, balancing administrative efficiency with fairness and due process protections. Courts support the Board’s role but ensure it operates within legal and procedural bounds.
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