John J. Ryan v. City of Providence

Summary

The Rhode Island Supreme Court vacated the Superior Court’s declaratory judgment, holding that Providence’s Honest Service Ordinance requires a criminal conviction (or guilty plea) before the retirement board may reduce or revoke a retiree’s pension. The Court reached that conclusion by applying plain‑meaning construction, the expressio unius canon, and the whole‑act rule, and therefore found the board lacked authority to act against Ryan. It declined to address the standard‑of‑review issue because the conviction prerequisite resolved the case. The opinion notes that the matter is remanded to the Superior Court for further proceedings.