Deputy sheriff's decade-old back injury claim exposes critical gap in public-sector appeal guidance
A state employee's disability pension appeal landed in the wrong court – and a new ruling makes clear where HR teams should be directing workers instead.
The Rhode Island Supreme Court ruled on March 16, 2026, that the Workers' Compensation Court had no authority to hear a state employee's challenge to a denied accidental disability pension. The decision draws a firm line between the appeal rights of state and municipal employees – a distinction that public-sector HR professionals cannot afford to overlook.
Sean M. O'Connell, a deputy sheriff with the Department of Public Safety, sustained a back injury in September 2011 and stopped working in April 2020. He filed for both ordinary and accidental disability retirement pensions in October 2021. The Employees' Retirement System of Rhode Island approved the ordinary pension but turned down the accidental disability request, finding that O'Connell had missed the filing deadline. Under state law, applications must be submitted within five years of the accident or three years of a reinjury or aggravation. His 2011 injury fell well outside that window, and he offered no evidence of an intervening event to reset the clock.
O'Connell pushed back. He submitted additional evidence arguing that his job duties between 2011 and 2020 had aggravated the original injury. The retirement board denied him again. He asked for a rehearing and a fresh medical examination. That, too, was denied. The board issued a final rejection letter and advised him that he could appeal to either the Superior Court or the Workers' Compensation Court, depending on the circumstances.
Taking the board at its word, O'Connell filed appeals in both courts. The retirement system moved to toss the Workers' Compensation Court case, arguing the court simply did not have jurisdiction over a state employee's pension dispute. The trial judge disagreed and let the case proceed. The retirement system then escalated the matter to the Supreme Court.
Associate Justice Melissa A. Long, writing for the court, overturned the trial judge. The Workers' Compensation Court, she explained, is a court with narrow, legislatively defined powers. It has authority over pension appeals under the Optional Retirement Plan for police officers and firefighters within the Municipal Employees' Retirement System – a plan designed primarily for municipal workers. Only a limited subset of state employees fall under that plan, specifically firefighters with occupational cancer and police officers with post-traumatic stress disorder.
O'Connell, who claimed a back injury rather than PTSD, did not qualify. His application was reviewed under the state retirement system's own disability provisions, which do not include any route of appeal to the Workers' Compensation Court. The court also pointed to a telling difference in the injured-on-duty statute: the section covering municipal employees explicitly references the Workers' Compensation Court, while the parallel section for state employees does not. That silence, the court found, was intentional.
The ruling means O'Connell's challenge will proceed in Superior Court under the Administrative Procedures Act, which is the proper venue for state employees contesting final agency decisions.
For HR teams in the public sector, the takeaway is practical and immediate. When a state employee is denied an accidental disability pension, the appeal path runs through Superior Court – not the Workers' Compensation Court. Misdirecting an employee, even in good faith, can cost valuable time and resources. The retirement board's own denial letter in this case pointed O'Connell toward both courts without specifying which applied to him – a vague phrasing that, as it turned out, led him down the wrong path.
The case also serves as a reminder that filing deadlines for disability retirement applications are strictly enforced. O'Connell's decade-long gap between his injury and his application proved fatal to his accidental disability claim, and no amount of additional evidence about on-the-job aggravation was enough to revive it.
