Pellegrino v. Rhode Island Ethics Commission

FLANDERS, J.,

concurring.

I write separately to note what I consider to be the legal consequences of the Court’s holding in this case that the plaintiffs acquired a protected property interest in the statutory benefit in question (a compensatory stipend for attending commission meetings). If, as alleged in the complaint, the plaintiffs attended the commission’s meetings during the period when the statute required the commission to pay such compensation, then the defendants’ alleged failure to compensate the plaintiffs would operate to take that property interest from them for the public’s use without paying the plaintiffs just com*1128pensation. The takings clause of the Rhode Island Constitution provides that “[p]rivate property shall not be taken for public uses, without just compensation.” R.I. Const, art. 1, sec. 16. Furthermore, this clause is a self-executing provision of our Constitution that needs no supplemental legislation to create a private cause of action for damages. See Bandoni v. State, 716 A.2d 580, 599 (R.I.1998) (citing Annicelli v. Town of South Kingstown, 463 A.2d 133 (R.I.1983)). See also DeBry v. Noble, 889 P.2d 428, 439 (Utah 1995) (adages such as “ ‘the sovereign can do no wrong’ ” or “the law giver cannot be made subject to a lawsuit” do not provide a valid rationale for a state sovereign’s immunity from alleged state constitutional violations); cf. Jones v. State of Rhode Island, 724 F.Supp. 25, 35 (D.R.I.1989) (Lagueux, J.) (holding that the Rhode Island State Constitution’s due-process clause in art. 1, see. 2, was added in 1986 to “‘create an independent state foundation for individual rights’” and thereby established “an implicit right to sue state actors for damages for violations of this newly created right”).

As the Connecticut Supreme Court has observed “[sovereign immunity does not protect [the] state * * * from suits to recover property taken or [held] in violation of the constitution or without statutory authority, even though the property is held in the name of the state * * *.” Simmons v. Parizek, 158 Conn. 304, 259 A.2d 642, 643 (1969). The principle of sovereign immunity, although deeply rooted in the common law, must give way to constitutional provisions like the just-compensation clause because “the source of governmental power and authority is not vested by divine right in a ruler but rests in the people themselves who have adopted constitutions creating governments with defined and limited powers and courts to interpret these basic laws.” Horton v. Meskill, 172 Conn. 615, 376 A.2d 359, 363 (1977). Perhaps the King could do no wrong, but a “government of the people, by the people, [and] for the people”3 is neither so infallible nor so immune from suit as monarchical regimes.

Moreover, it would be inconsistent to hold, on the one hand, that the people of this state have a constitutional right to just compensation for governmental takings of private property for public uses, while, on the other, holding that they are prevented from suing the state government to obtain just compensation because of sovereign immunity. Cf. Corum v. University of North Carolina, 330 N.C. 761, 413 S.E.2d 276, 292 (1992) (“when there is a clash between these constitutional rights and sovereign immunity, the constitutional rights must prevail”). Furthermore, it is a bedrock principle of legal construction that constitutional rights trump common-law doctrines like sovereign immunity. “In a constitutional democracy sovereign immunity must relax its bar when suits against the government complain of unconstitutional acts.” Sentner v. Board of Trustees of Regional Community Colleges, 184 Conn. 339, 439 A.2d 1033, 1036 (1981). Therefore, because in this state, as in other jurisdictions, “the doctrine of sovereign immunity is not a constitutional right; [but] a common law theory or defense established by [courts] * * * when there is a clash between these * * * rights * * *, the constitutional rights must prevail.” Corum, 413 S.E.2d at 292.

For these reasons, and for those set forth in the Court’s opinion, which I join, I concur with the disposition of this appeal.

. Abraham Lincoln, The Gettysburg Address (Nov. 19, 1863).