In Angell v. Union Fire District of South Kingstown, 935 A.2d 943 (R.I. 2007), the Court considered whether a volunteer fire fighter was covered under § 45-19-1.
There, the court noted that "the resolution of the case . . . rested in large part on the definition of 'employed' as it is used in" the statute. Id. at 946.
After finding that an "employee" is one who works for compensation and that the Legislature included separate statutory provisions for volunteer firefighters, the court concluded that volunteer firefighters are not covered by § 45-19-1. See id. at 947.