The Rhode Island Supreme Court affirmed a Superior Court judgment dismissing a declaratory relief action filed by Clifton Peasley against the City of Providence and its Treasurer Shomari Husband, applying the election of remedies doctrine in a decision that reinforces limits on pursuing multiple legal avenues for the same dispute.
In *Peasley v. City of Providence* (R.I. 2025), Justice Goldberg wrote for the unanimous court in case No. 2025-21-Appeal, explaining that the trial court properly applied equitable principles when it determined that Peasley had already elected his remedy by pursuing the city's grievance process to challenge the denial of his back pay claim.
The election of remedies doctrine prevents parties from pursuing multiple inconsistent legal remedies for the same wrong. This equitable principle requires a party to choose between available remedies and bars subsequent actions once a remedy has been elected and pursued.
The case originated when Peasley filed an action for declaratory relief against Providence after the city denied his claim for back pay. However, the trial justice found that Peasley had previously employed the grievance process available through the city to challenge this same denial, effectively electing that remedy.
The Superior Court trial justice dismissed Peasley's declaratory relief action, reasoning that allowing the lawsuit to proceed would violate the election of remedies doctrine since Peasley had already chosen to pursue his claim through the administrative grievance procedures established by the city.
Peasley appealed the dismissal to the Rhode Island Supreme Court, challenging the application of the election of remedies doctrine to his case. The Supreme Court heard the matter on December 2, 2025, pursuant to an order to show cause, a procedural mechanism that allows the court to determine whether sufficient grounds exist to proceed with the appeal.
After reviewing both written submissions and oral arguments from the parties, the Supreme Court concluded that Peasley had not shown cause to reverse the trial court's decision. Justice Goldberg, writing for the five-member court that included Chief Justice Suttell and Justices Robinson, Lynch Prata, and Long, affirmed the Superior Court's judgment.
The court's analysis focused on the fundamental principles underlying the election of remedies doctrine. This equitable principle serves several important purposes in the legal system, including promoting judicial economy, preventing inconsistent judgments, and ensuring fairness by requiring parties to commit to a chosen course of action rather than pursuing multiple avenues simultaneously.
In applying the doctrine to Peasley's case, the court emphasized that the plaintiff had made a deliberate choice to pursue the city's grievance process as his initial remedy for challenging the back pay denial. Having elected this administrative remedy and pursued it to completion, Peasley was barred from subsequently filing a separate court action seeking declaratory relief on the same underlying dispute.
The decision reflects the broader legal principle that parties cannot pursue multiple remedies for the same alleged wrong, particularly when those remedies are inconsistent or could lead to conflicting outcomes. The election of remedies doctrine requires parties to make strategic decisions about which legal avenue to pursue and prevents them from hedging their bets by pursuing multiple concurrent actions.
For municipal employees and others dealing with government entities, the ruling serves as an important reminder about the consequences of choosing administrative remedies. Once an employee elects to pursue a grievance process or other administrative remedy, that choice may preclude subsequent court actions on the same matter.
The case also demonstrates the Rhode Island Supreme Court's willingness to apply established equitable principles to prevent abuse of the legal system. By affirming the dismissal, the court reinforced that litigants must make meaningful choices about their legal strategies rather than pursuing every available option.
The opinion, issued as Supreme Court case No. 2025-21-Appeal, remains subject to formal revision before publication in the Rhode Island Reporter. The court's standard notice indicates that readers may notify the Opinion Analyst of any typographical or formal errors for correction before final publication.
This decision adds to Rhode Island jurisprudence on the election of remedies doctrine and provides guidance for future cases involving disputes between individuals and municipal entities. The ruling clarifies that the doctrine applies with equal force to cases involving government defendants and reinforces the importance of strategic decision-making in legal proceedings.
The case underscores the practical implications of the election of remedies doctrine in employment-related disputes with government entities, where multiple procedural avenues may initially appear available but where pursuing one remedy may foreclose others.