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Curt VaroneJune 30, 2025
127

Hawaii Court Affirms That Paid Leave Pending Investigation is Not Discipline

The Intermediate Court of Appeals of Hawaii has concluded that the placement of firefighters on paid administrative leave pending the…
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Curt Varone has over 50 years of fire service experience and 40 as a practicing attorney licensed in both Rhode Island and Maine. Besides his law degree, he also has a master’s in forensic psychology. His fire service background includes 29 years as a career firefighter in Providence (retiring as a Deputy Assistant Chief), as well as volunteer and paid-on-call experience.

He is the author of three books: Legal Considerations for Fire and Emergency Services (2006, 2nd ed. 2011, 3rd ed. 2014, 4th ed. 2022), Managing Disciplinary Challenges in the Fire Service (2026), and Fire Officer's Legal Handbook (2007), and is a contributing editor for Firehouse Magazine, writing the Fire Law column.

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Hawaii Court Affirms That Paid Leave Pending Investigation is Not Discipline