Massachusetts appellate court concludes that arbitrators do not need specific authority to modify disciplinary punishment, where the bargaining agreement requires "just cause."

     A Boston police officer was given a three-day suspension for conduct unbecoming an officer. The arbitrator reduced the penalty to a written reprimand. Management sought judicial review, claiming there is no contractual authority for arbitrators to modify the punishment.

     In court, the union argued that because the bargaining agreement prohibited discipline or discharge "without just cause," the arbitrator must review the severity of the penalty that has been imposed.

     The city claimed that the arbitrator "was authorized to consider only whether the facts justified the imposition of discipline at all, and, if so, that the discipline imposed was beyond the scope of the parties' referral."

     A three-judge appeals panel said that "we are satisfied that the severity with which this municipal employer treats its police officers in disciplinary proceedings can be the subject of a grievance."

     They noted that bargaining agreements usually do not limit the arbitrator's power to formulate remedies and that arbitrators have consistently held that an excessively harsh penalty for misconduct violates the requirement for just cause.

     Boston Police Patrolmen's Association v. City of Boston, #02-P-883, 60 Mass. App. Ct. 672, 805 N.E.2d 80, 2004 Mass. App. Lexis 298 (2004).

     • Click here to view the decision on the Internet.

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Appeals court holds that a sergeant could testify against officers at a disciplinary hearing, based on what he was told by a citizen. Hearsay evidence is admissible if reliable, and was based on an investigative interview of an eyewitness.

     Two NOPD officers were given 15-day suspensions for failing to file an domestic violence report. The victim was found dead two days later. The officers claimed there was no evidence of physical injuries, and a report was not mandatory under that circumstance.

     However, a sergeant was prepared to testify that the person who had summoned the police had informed him that the woman was visibly bruised or scratched at the time that he had made the call.

     The Civil Service Commission would not allow that testimony, because the accused officers would not be able to cross-examine the citizen, who was absent from the proceedings.

     A three-judge appellate panel reversed. They said:

"In the instant case, the issue is not whether hearsay evidence is admissible in administrative hearings. Clearly, such evidence may be admissible if it is competent evidence. Thus the question becomes whether [the sergeants'] testimony regarding [the citizen's] observations was competent evidence.

"Sergeant T__ interviewed [the citizen] during the course of an administrative investigation of the officers' actions during the domestic disturbance call. Sergeant T__ had the opportunity to evaluate [the citizen's] credibility and his truthfulness during the interview. [The citizen] maintained his contention that the female was visibly bruised or scratched at the time [he] made the call to the police.

     The panel said that the commission erred in disallowing the hearsay testimony of the sergeant when the lay witness failed to testify. Based on the testimony of the sergeant, there was evidence to support disciplinary action against the officers on both the neglect of duty and the untruthfulness charges. The suspensions were reinstated.

     Broaden v. Dept. of Police, #2003-CA-1427, 866 So.2d 318, 2004 La. App. Lexis 16 (La. App. 4th Cir. 2004).

     • Click here to view the decision on AELE's website.

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DC Bar joins Virginia in ruling that government attorneys ethically may engage in fraud, deceit, or misrepresentation if they reasonably believe that their official duties require covert action.

     Last year we reported that the Virginia Bar Rules of Professional Conduct, which prohibit "conduct involving dishonesty, fraud, deceit or misrepresentation," did not apply to government lawyers employed by an intelligence or law enforcement agency, when adjunct to their official duties.

     The District of Columbia Bar has adopted a similar exception to include the "misrepresentations made in the course of official conduct as an employee of an agency of the United States if the attorney reasonably believes that the conduct in question is authorized by law." Opinion 23: "Misrepresentation by an Attorney Employed by a Government Agency as Part of Official Duties."

     • Click on link to view D.C. Bar Legal Ethics Opinion 323, 42 (2054) G.E.R.R. (BNA) 357 (3/30/2004) or Virginia State Bar Ethics Opinion 1765, 41 (2019) G.E.R.R. (BNA) 768 (6/13/03).

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Arbitrator reduces penalty from 3 days to 1 day for violating a rule prohibiting more than two marked cars parked at the same restaurant. A prior disciplinary incident occurred 5 years earlier and was not for related conduct.

     The Quiznos in Elgin, Illinois is a popular sandwich shop with police officers. However, the police dept. had a rule that no more than two marked police units may be at any location while taking a meal break.

     A patrol officer was docked three-days pay for violating the rule, in part because he had "similar" rule violations in the past. On appeal, the arbitrator reduced the punishment to one day.

     Although the grievant had a prior disciplinary record, it consisted of a reprimand for a January, 1999 traffic accident and a three-day suspension in 1997 for insubordinate behavior.

     These were unrelated to the present infraction and remote enough in time to break the "ladder of progression."

     City of Elgin Police and PBA 54, 119 LA (BNA) 517, Arb. #02/074 Goldstein, (2003; Rptd. 2004).

     • Click here to view the award on AELE's website.

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Fifth Circuit reinstates a wrongful termination suit, filed by a police sergeant who claimed he was fired for responding to a news reporter's questions about a possible cover-up of the use of excessive force by another officer. The fact the sergeant also may have had an interest in vindicating himself did not take away from the "public" nature of the inquiry.

     A Texas police sergeant reported to an internal affairs captain that subordinate had used excessive force while arresting a citizen. The I-A investigation concluded that the officer had used excessive force but that the sergeant was innocent of any wrongdoing.

     The citizen then sued the city and several others, including the sergeant and the concerned officer. The chief of police distributed a memo to all police employees advising them not to discuss this case with anyone except for attorneys hired by Texas Municipal League.

     The sergeant had spoken to a reporter "off the record" before the memo was sent. However, after the memo he granted the reporter an interview. At that time he criticized the officer's actions and said that he had been ordered to file two incident reports -- one with what [the accused officer] did and one without what [he] did." The article further quoted the sergeant as saying, "In 20 years I've never been asked to do two reports on anything I've ever done - especially leaving anything out of one and putting it in the other."

     After the article ran, the chief permanently demoted from him to patrol officer, and placed him on disciplinary probation. After the probationary period, he was fired for a "failure to issue traffic tickets."

     The ex-sergeant sued, but the federal district court found that the speech did not involve a matter of public concern. On appeal a three-judge panel noted that to establish a First Amendment retaliatory discharge claim, a plaintiff must prove that (1) he suffered an adverse employment action, (2) his speech involved a matter of public concern, (3) his interest in commenting on the matter of public concern outweighed the defendant's interest in promoting efficiency, and that (4) his speech was a substantial or motivating factor behind the defendant's actions.

     The first part was obvious; the second part was murkier, because his interview involved both matters of public concern and a private dispute with management. They said that "public employees ... may make valuable contributions to public debate... Information regarding an attempted cover up by police is best obtained from a department insider ..." Additionally, the journalist approached the plaintiff.

     The panel noted that "sister circuits have found, and we agree, that the fact that the speaker was approached by a journalist weighs in favor of a finding that the speech involved a matter of public concern, even if the plaintiff had a personal stake in the subject being discussed."

     The district court was reversed, and the matter sent for trial. Markos v. City of Atlanta, Texas, #03-40140, 2004 U.S. App. Lexis 5423 (5th Cir. 2004).

     • Click here to view the opinion on the Internet. [PDF]

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After the Mississippi Highway Patrol loses a motion to dismiss a DoJ suit, filed on behalf of a cadet with diabetes who was fired, the agency agrees to pay damages and change its policies of accommodation.

     The suit alleged that the Patrol refused to allow a recruit a reasonable accommodation for his diabetes, and unlawfully terminated him due to that disability.

     The cadet made several requests for additional food at more frequent intervals in order to control his diabetes, in light of the strenuous exercise. His requests were denied and he suffered hypoglycemia, causing him to be confused and unable to report to training. The Highway Patrol dismissed him from the academy.

     In January, a federal court refused to grant a defense motion for summary judgment. Two months later, the state agreed to pay the ex-cadet $35,000 in damages. The Patrol also agreed to implement a reasonable accommodation policy, to educate its training officers on the policy and how to recognize diabetes and other disabilities.

     U.S.A. v. Miss. Dept. of Pub. Safety, #3:00-CV-377, 2004 U.S. Dist. Lexis 4633, 15 AD Cases (BNA) 672 (S.D. Miss. 2004); settlement announced, DoJ Press Release CR-04-196.

     • Click link to view the opinion on the AELE website and the DoJ Press Release.

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Federal appeals court declines to hold that an officer was forced off the job because he failed to uphold an unlawful ticket quota. The officer was not asked to violate the law, but merely to improve his traffic enforcement work.

     The officer resigned from an Iowa police dept. after a negative evaluation and his reassignment for remedial training for issuing a low number of traffic tickets. He sued the city in alleging due process and constructive discharge claims.

     A three-judge appeals panel affirmed the lower court. "The police department simply implemented an employment policy for evaluating one component of an officer's performance based on the number of tickets the officer has written versus the shift average."

     The negative evaluation and training requirement did not create "working conditions so intolerable that he was forced to resign involuntarily." Hendriks v. City of Muscatine, #03-2541, 2004 U.S. App. Lexis 5088 (8th Cir. 2004).

     • Click here to read the unpublished decision on AELE's website.

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OSHA cites the U.S. Forest Service for five violations arising from the deaths of two firefighters in July 2003.

     Two Forest Service firefighters were killed near Salmon, Idaho, while clearing a helicopter landing area. The OSHA citation charges that the Service violated "all of the Ten Standard Fire Orders" as well as 14 of the 18 "Watch Out Situations" listed in a national handbook for fighting forest fires.

     Because the Forest Service is a federal agency, OSHA can issue citations but cannot attach penalties for violations, as would apply to the private sector. OSHA penalties go as high as $70,000 per willful violation.

     The violations included failure to:

1. conduct fire complexity analysis.
2. provide additional supervisory and suppression support.
3. maintain and calibrate automated weather stations.
4. conduct inspections of fire operations for safety and health hazards.

     Among other things, OSHA said that the service delegated inadequately trained employees to identify, evaluate, and correct hazards related to complex wild land fire safety.

     The Forest Service has agreed to create Hazard Abatement Plan, which would include changes in training programs and certification procedures. Dept. of Labor v. U.S.D.A. Forest Service, #1177886150, 42 (2054) G.E.R.R. (BNA) 345 (OSHA 2004).

     • Click link to view the PDF Citation for willful conduct and the USDA Cramer fire fatalities Summary.

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Federal court holds that the Delaware State Police used too high a cutoff score on a reading ability test, resulting in a high rejection rate for black applicants. DoJ will now seek remedial relief.

     A federal court has found that Delaware failed to show that its minimum required score on a state trooper reading and writing entrance exam was job related. The scoring resulted in the rejection of a disparate number of black applicants.

     The "Alert" test consisted of 160 multiple-choice questions "designed to assess the candidate's reading comprehension, writing, and grammar skills." The DSP relied on the advice of the test's author and vendor, and set the minimum passing score for the test at 75%.

     The suit was brought by the Justice Dept., who alleged that in a 9+ year period from 1989-1998, the DSP hired only 26 black troopers, or about 8 percent of all those hired.

     The judge noted that 18 applicants had initially failed the test but passed on a retake, and 14 went on to successfully serve as state troopers. Other applicants who failed the test were later hired by other law enforcement agencies, including the U.S. Secret Service.

     The DoJ intends seek a court order requiring the state to make job offers, plus back pay and retroactive seniority. U.S. v. Delaware State Police, #01-020, 2004 U.S. Dist. Lexis 4560 (D. Del. 2004).

     • Click here to view the court's Findings and Conclusions (and earlier opinion) on AELE's website. The DoJ press release is on the Internet.

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Employers will be able to reduce or eliminate retired workers' health benefits after they qualify for Medicare, under a revised Rule of the Equal Employment Opportunity Commission.

     The U.S. Equal Employment Opportunity Commission has voted 3-to-1 to approve a proposed final rule that would permit employers, under the Age Discrimination in Employment Act, to "coordinate" retiree health benefit plans with Medicare.

     The General Accounting Office has estimated that 10 million retired individuals aged 55+ have employer-sponsored health plans as either their primary source of health coverage or as a supplement to Medicare.

     The Commission's prior policy, which was rescinded by a unanimous vote in August 2001, had concluded that coordinating retiree health benefits with Medicare eligibility constituted an illegal age-based distinction under the ADEA. Then, on July 14, 2003, the EEOC published a proposed new Rule in the Federal Register and solicited public comments .

     Under Executive Orders 12067 and 12866 the Rule will be reviewed by other federal agencies including the Office of Management and Budget. U.S. Equal Employment Opportunity Commission Notice of Proposed Rulemaking: Age Discrimination in Employment Act -- Retiree Health Benefits, 68 (134) Fed. Reg. 41542 (July 14, 2003).

     • Click here to read the proposed rule on the GPO website. [PDF]

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Pennsylvania appellate court affirms an arbitration award that a state trooper's involuntary transfer from a desired assignment was disciplinary and arbitrable.

     Most bargaining agreements allow management to order lateral transfers for the good of the service. If a transfer is punitive, the employee usually is entitled to challenge the reassignment by grievance.

     A state trooper challenged his transfer from the aviation unit. Management claimed the action was nondisciplinary. When the dispute came to a hearing, the arbitrator defined discipline as any action that

(1) results in an adverse personnel consequence, and
(2) is in response to willful and undesirable behavior.

     The first part was satisfied because the trooper had to go through a rigorous selection process to get the assignment, which he held for more than six years. Moreover, removal from a specialized unit carried a "stigma of failure" and implied the employee was deficient to some degree.

     As for the second part, the arbitrator found that the transfer was the result of a captain's conclusion that the trooper had a negative attitude, which the captain believed "constituted a danger" to the unit's operations.

     Although the captain claimed that the transfer was nondisciplinary, the attitude assessment must have been the result of conduct perceived as undesirable.

     The arbitrator annulled the transfer. Management had the right to make nondisciplinary transfers from specialized positions without arbitral interference, but this transfer was disciplinary and therefore grievable.

     Management sought judicial review, claiming that the arbitrator exceeded his powers. A three-judge appellate court affirmed. Citing two prior cases, the panel said that the arbitrator had authority to set aside the transfer as nondisciplinary. City of Philadelphia v. FOP L-5, #J-134-2000, 564 Pa. 290 at 299, 768 A.2d 291 at 296-97 (2001); Fairview Twp. v. Fairview Twp. Police Assn., 1694 C.D. 2001, 795 A.2d 463 (Pa. Cmwlth. 2002). [PDF]

     The appellate panel noted that the transfer could have been justified if management had offered reasons to impose disciplinary action. Instead, management insisted the transfer was nondisciplinary and not reviewable. Penn. State Police v. Penn. State Troopers Assn., #1815 C.D. 2003, 840 A.2d 1059, 2004 Pa. Commw. Lexis 18, 174 LRRM (BNA) 2154 (2004).

     • Click here to view the decision on the Internet. [PDF]

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Illinois appeals court upholds a Labor Board ruling ordering a police union to stop refusing to process grievances of officers who gather signatures to have another union designated as the bargaining agent.

     In 1999 a Cook County corrections officer began circulating a petition to have the Teamsters replace the current union as the exclusive bargaining representative.

     Shortly thereafter the officer was suspended for sleeping on duty. He submitted a grievance challenging the suspension. After the grievance was denied he requested the union to pursue the grievance to arbitration. The union declined to do so.

     The union responded that in collecting signatures for the Teamsters, that action "would nullify this union for pursuing any grievances ..." He then filed an Unfair Labor Practice charge against the union with the state Labor Board.

     He alleged that the "union had refused to arbitrate the grievance in retaliation for his activities in support of ... the Teamsters" and sought to have his grievance arbitrated or be reimbursed for the two days he was suspended.

     The Labor Board ordered the union to cease and desist from threatening not to pursue grievances" on behalf of the officer and from refusing to arbitrate or any other employee's grievance because of his support of a rival labor organization.

     The union sought judicial appeal. A three-judge appellate panel affirmed the Board's action, saying:

     "The exclusive agent's statutory authority to represent all members of a designated unit includes a statutory obligation to serve the interests of all members without hostility or discrimination toward any, to exercise its discretion with complete good faith and honesty, and to avoid arbitrary conduct."

     Metrop. Alliance of Police v. Illinois Lab. Rel. Bd., #1-02-0960, 345 Ill.App.3d 579, 803 N.E.2d 119, 2003 Ill. App. Lexis 1563, 174 LRRM (BNA) 2043 (2003, released 2004).

     • Click here to read the decision on the Internet

     Research Note: The union's duty to represent an employee is not absolute, as illustrated by two recent cases -- neither of which involved a claim that representation was declined because the grievant supported a rival union.

      »In Connecticut, a federal court ruled that a police union did not act arbitrarily or breach its duty of fair-representation in failing to respond to all steps in the grievance filed by a police detective who challenged his removal from the department's emergency response team for allegedly violating the code of conduct. Barton v. City of Bristol, #3:02CV1210, 294 F.Supp.2d 184, 2003 U.S. Dist. Lexis 21623, 173 LRRM (BNA) 3045 (Conn. 2003).

      »In Pennsylvania, a federal court held that a union did not act arbitrarily, discriminatorily, or in bad faith in breach of its fair-representation duty when it withdrew from arbitration proceedings in behalf of a civilian employee who was fired for possessing a deadly weapon on the agency's premises, verbal assault, and engaging in conduct unbecoming, where union assisted the employee at all steps of the grievance procedure. Yon v. SEPTA, #01-5231, 2003 U.S. Dist. Lexis 20189, 173 LRRM (BNA) 3025 (E.D. Pa. 2003).

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Age Discrimination - Termination / Mandatory Retirement

     Federal appeals court dismisses a claim that Chicago's mandatory retirement program for police officers and firefighters was subterfuge to evade the purposes of the ADEA. Because the ADEA expressly permits retirement programs, the fact that city officials exercised this right for impure motives does not establish a subterfuge. Minch v. City of Chicago, #02-2587, 2004 U.S. App. Lexis 6927 (7th Cir. 2004). [PDF]

Civil Service

     California Supreme Court depublishes an appellate court decision that upheld "post and bid" programs established under collective bargaining agreements, which apply to a limited number of appointments and promotions for civil service classifications. Calif. St. Personnel Board v. Calif. St. Employees Assn. L-1000, #C0242437,114 Cal.App.4th 11, 7 Cal.Rptr.3d 243, 2003 Cal. App. Lexis 1816 (Cal. App. depub.) review granted, 2004 Cal. Lexis 1664 (2004).

     H.R 1588-230, which created the Dept. of Defense National Security Personnel System, changes the way the DoD will hire, pay, promote, discipline and fire its 320,000 civilian employees. The legislation effects members of more than 1,300 local bargaining units. [PDF]

Disciplinary Punishment - In General

     Appeals court upholds termination of an officer for soliciting a prostitute. The evidence was based on surveillance and questioning of the woman. Weir v. Bratton, #2862, 772 N.Y.S.2d 38, 2004 N.Y. App. Div. Lexis 1660 (2004).

     West Virginia Supreme Court holds that the failure of management to consider the 15-year excellent work record of the chief investigator for the state medical examiner's office when it discharged him is sufficient reason to restore him to his original position or an equivalent one. The investigator established a prima facie case of reprisal and was made a scapegoat for the actions of several employees. Sloan v. Dept. of Health, #31374, 2004 W. Va. Lexis 6, 20 IER Cases (BNA) 1788 (W.Va. 2004).

Discovery, Publicity and Media Rights

     Supreme Court finds that the release of gruesome body photos is not required under the FOIA's exception for "records or information compiled for law enforcement purposes" if their production "could reasonably be expected to constitute an unwarranted invasion of personal privacy." National Archives v. Favish, 02-954, 124 S.Ct. 1570, 2004 U.S. Lexis 2546 (2004) construing 5 U.S. Code §552(b)(7)(C).

     Federal court rules that curious historians did not have legal standing to challenge Executive Order 13233, by which the heirs of a deceased or disabled former president can block public access to Presidential records. American Historical Assn. v. National Archives, #01-2447, 2004 U.S. Dist. Lexis 5137 (D.D.C. 2004). [PDF]

Divorce Proceedings

     Four years after a police officer began participating in a DROP plan, he and his wife were divorced. A Texas appellate court has held that the wife was entitled to a percentage of the benefits credited to the husband's DROP [Deferred Retirement] account, including those credited post-divorce. Stavinoha v. Stavinoha, #14-02-01081-CV, 126 S.W.3d 604, 2004 Tex. App. Lexis 465 (2004).

Free Speech

     Seventh Circuit finds that a former city worker was entitled to summary judgment; the record shows that he was fired in retaliation for exercising his right of free speech. Gazarkiewicz v. Town of Kingsford Heights, #03-2775, 359 F.3d 933, 2004 U.S. App. Lexis 4349, 20 IER Cases (BNA) 1823 (7th Cir. 3004). [PDF]

Hearing (Audio) Impairment

     A police officer's hearing loss, that was sustained over a long period of time while controlling crowds at parades and other events, was not the result of an accident. Hoehl v. Kelly, #2941, 772 N.Y.S.2d 65, 2004 N.Y. App. Div. Lexis 1840 (2004).

Occupational Safety & Disease

     California appeals court orders a law enforcement firing range to undertake an environmental study to justify its decision to close and remove a campus shooting range and to transfer certain classes to another range off campus. Assn. for a Cleaner Environment v. Yosemite Comm. College Dist., #F042272, 116 Cal. App. 4th 629, 10 Cal. Rptr.3d 560, 2004 Cal. App. Lexis 276 (5th App. Dist. 2004). [PDF]

Pay Disputes - Overtime Claims

     The Federal Labor Relations Authority has ruled held that federal criminal investigators whose lunch breaks were interrupted by supervisor work requests can count the response time as duty time. INS and AFGE L-3983, #0-AR-3710, 59 FLRA No. 102, 2004 FLRA Lexis 6 (FLRA 2004).

Pregnancy Policies and Discrimination

     Although state police management involuntarily placed pregnant troopers on light duty when they were unable to perform 131 tasks that no state police officer "was likely ever to perform," including roping a steer and lifting a 800-pound motorcycle to an upright position, the women were not entitled to recover damages against the medical personnel for "extreme and outrageous" conduct. Butner v. Dept. of State Police, #02-P-390, 60 Mass.App.Ct. 461, 803 N.E.2d 722, 2004 Mass. App. Lexis180, 93 FEP Cases(BNA) 602 (2004).

Retirement Rights and Benefits

     California appellate court concludes that a payment for accumulated sick leave is not part of a public employee's "final compensation" under Government Code 31461 and 31461.2 and should not be included when calculating retirement benefits. Salus v. San Diego Co. Emplees. Assn., #D041608, 2004 Cal. App. Lexis 478 (4th Dist. 2004). [PDF]

Sexual Harassment - In General

     Supervisory state polices officers were not entitled to qualified immunity in case alleging deliberate indifference toward a male trooper's sexual harassment of women, where they failed to adequately supervise the male officer, although they knew of his history of sexual misconduct. Maslow v. Evans, #01-CV-3636, 2003 U.S. Dist Lexis 20316, 2003 WL 22594577 (E.D. Pa. 2003).

Sexual Harassment - Retaliation

     Appeals court allows a state trooper, who was disciplined after she complained about a hostile environment (because her boss was engaged in sexual favoritism toward his assistant) to proceed with a retaliation claim under the state civil rights law. Ritchie v. Dept. of State Police, #02-P-593, 60 Mass.App.Ct. 655, 805 N.E.2d 54, 2004 Mass. App. Lexis 297 (2004).

Stress Related Claims and Defenses

     NYC judge overturns decision to deny disability benefits to a former NYPD internal affairs officer that uncovered corruption and then (a) suffered harassment by a few anonymous coworkers, (b) was given undesirable assignments and (c) was subjected to the silent treatment by other officers. Matter of Jeffrey W. Baird v. Kelly, #101889/2003, N.Y. Law J. (N.Y. Co. Sup. Ct. 4/6/2004).

Untruthfulness & Resume Fraud

     An employee cannot use the FMLA (or other civil rights laws) to claim retaliatory termination when he was properly fired for falsifying his job-application, and there was no evidence that the employer's rule punishing untruthful applications is applied more harshly to employees who make legal claims against the company than against other employees who falsify their applicant forms. Aubuchon v. Knauf, #03-1382, 359 F.3d 950, 2004 U.S. App. Lexis 4347, 9 WH Cases2d (BNA) 711 (7th Cir. 2004). [PDF]

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     Overtime: The Dept. of Labor's new rules on overtime are explained at a new "FairPay" website.

Reference:

     • Abbreviations of Law Reports, laws and agencies used in our publications.
     • AELE's list of recently noted employment law resources.  
     • Discrimination Laws plus EEOC Regulations and Policy Guidance

CROSS REFERENCES