AFGE v. D.C. Water & Sewer

CourtDistrict of Columbia Court of Appeals
DecidedAugust 8, 2024
Docket23-CV-0185
StatusPublished

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AFGE v. D.C. Water & Sewer, (D.C. 2024).

Opinion

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DISTRICT OF COLUMBIA COURT OF APPEALS

No. 23-CV-0185

AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES AFL-CIO, LOCAL 872, APPELLANT,

v.

DISTRICT OF COLUMBIA PUBLIC EMPLOYEE RELATIONS BOARD, APPELLEE.

and

DISTRICT OF COLUMBIA WATER AND SEWER AUTHORITY, INTERVENOR.

Appeal from the Superior Court of the District of Columbia (2022-CA-002435-P(MPA))

(Hon. Shana Frost Matini, Trial Judge)

(Submitted April 24, 2024 Decided August 8, 2024)

Barbara B. Hutchinson was on the brief for appellant.

Geoffrey H. Simpson and Bruce A. Fredrickson were on the brief for appellee.

Tina M. Maiolo and Stephen G. Rutigliano were on the brief for intervenor.

Before BLACKBURNE-RIGSBY, Chief Judge, and HOWARD and SHANKER, Associate Judges. 2

HOWARD, Associate Judge: This case concerns negotiations over COVID-19

vaccination and return-to-work requirements between appellant American

Federation of Government Employees AFL-CIO, Local 872 (“AFGE”) and

intervenor D.C. Water and Sewer Authority (“D.C. Water”). The vaccination and

return-to-work requirements followed a COVID-19 public health emergency

declaration by the Mayor and corresponding emergency legislation by the Council

of the District of Columbia. Both have expired. In fact, since this litigation began,

the District has rescinded its vaccination requirement and its employees have

returned to work. We agree with appellee Public Employee Relations Board

(“PERB”) that there is no reasonable likelihood that D.C. Water will use two

emergency authorities—D.C. Code §§ 1-617.08(a)(6) and 7-2304(b)(16)—to

impose vaccination or return-to-work requirements without bargaining. We

therefore dismiss this appeal as moot.

I. Background

We describe two applicable statutes before summarizing relevant factual and

procedural history. 3

A. Statutory Framework

In 1978, the Council enacted the Comprehensive Merit Personnel Act to

replace a “disjointed” and “decentralized” system with a “uniform” system for

administering District of Columbia personnel matters. See Coleman v. District of

Columbia, 80 A.3d 1028, 1031 (D.C. 2013) (summarizing history of the CMPA);

D.C. Code § 1-601.02(a)(2) (describing purpose of the CMPA). Elements of the

new, uniform system include a subchapter governing labor-management relations,

see D.C. Code § 1-617.02 (describing scope and content), that, as relevant here,

allows management “[t]o take whatever actions may be necessary to carry out the

mission of the District government in emergency situations,” id. § 1-617.08(a)(6).

Only the PERB and labor-management parts of that system apply to employees of

D.C. Water. See D.C. Code § 34-2202.15(a)(1) (making merit personnel system

inapplicable to D.C. Water except for PERB and labor-management subchapters);

see also Am. Fed’n of Gov’t Employees v. District of Columbia Water & Sewer

Auth., 942 A.2d 1108, 1113 (D.C. 2007) (stating same).

In March 2020, the World Health Organization declared COVID-19 to be a

pandemic; the Mayor then declared the COVID-19 pandemic to be a public health

emergency. See District of Columbia v. Towers, 250 A.3d 1048, 1050-52 (D.C.

2021) (per curiam) (recounting history of the Mayor’s public health emergency 4

declaration). The Council then enacted the COVID-19 Response Emergency

Amendment Act of 2020, D.C. Act 23-247, 67 D.C. Reg. 3093 (Mar. 17, 2020)

(“COVID-19 Emergency Act”). Section 301 of the COVID-19 Emergency Act

amended D.C. Code § 7-2304(b) to state that, “[n]otwithstanding any provision of

the [CMPA] . . . or any other personnel law or rules,” the Mayor could take actions

“regarding executive branch subordinate agencies that the Mayor determines

necessary and appropriate to address the emergency.” These actions included items

like mandating telework or reassigning employees within or between agencies. Id.

B. Factual and Procedural History

About six months later, on September 1, AFGE and D.C. Water entered into

a Memorandum of Agreement (“MOA”) to address working conditions for AFGE

employees. The next year, the MOA expired on September 30, 2021. The parties

then bargained over working conditions. However, differences arose regarding

“conditions for returning to work, availability of leave, administrative requirements

related to the vaccinations, and notice to employees of a confirmed coronavirus.”

Fifteen days after the MOA expired, on October 15, 2021, AFGE filed a

Request for Expedited Impasse Resolution with PERB. The executive director of

PERB referred the parties to mediation, which did not resolve the dispute. AFGE

then asked PERB on November 16, 2021, to order interest arbitration. D.C. Water 5

moved to dismiss the request, contending that there was no impasse as to any of the

terms at issue.

On January 13, 2022, PERB granted D.C. Water’s motion to dismiss. PERB

cited D.C. Office of Labor Relations and Collective Bargaining v. D.C. Publ. Emp.

Relations Bd., Civil Action No. 2020 CA 003086 P(MPA) (D.C. Super. Ct. Sept. 29,

2021) (“OLRCB v. PERB”), a Superior Court decision that concluded that the

COVID-19 Emergency Act gave agencies a management right to enact personnel

actions in emergency situations without bargaining. PERB concluded that the

management right applied to D.C. Water’s vaccination requirements, return-to-work

policies, COVID-19 administrative leave policy, and impacts and effects of those

policies. AFGE requested that PERB reconsider. PERB denied reconsideration,

asserting that the disputed management rights were non-negotiable.

AFGE then petitioned for review in Superior Court, which dismissed the

petition on February 14, 2023. The trial court first stated that while D.C. Water is

an “independent authority of the District government,” see D.C. Code § 34-2202.02,

the labor-management provisions of the CMPA apply to D.C. Water. See D.C. Code

§ 34-2202.15(a)(1). Agreeing with PERB, the trial court concluded that the

COVID-19 Emergency Act “specifically alters the labor-management rights and

relations during the COVID-19 pandemic for all covered entities, including [D.C. 6

Water],” and that PERB had reasonably interpreted the COVID-19 Emergency Act

and the CMPA in concluding so. Put another way, because “[t]he management

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