AFSCME v. City of Las Vegas

New Mexico Court of Appeals·Decided February 4, 2019·No. A-1-CA-35840·Unpublished

Opinion

This memorandum opinion was not selected for publication in the New Mexico Appellate Reports. Please see Rule 12-405 NMRA for restrictions on the citation of unpublished memorandum opinions. Please also note that this electronic memorandum opinion may contain computer-generated errors or other deviations from the official paper version filed by the Court of Appeals and does not include the filing date.

1 IN THE COURT OF APPEALS OF THE STATE OF NEW MEXICO

2 AMERICAN FEDERATION OF STATE, 3 COUNTY AND MUNICIPAL EMPLOYEES, 4 COUNCIL 18, AFL-CIO, LOCAL 2851,

5 Appellant-Petitioner, 6 v. NO. A-1-CA-35840 7 CITY OF LAS VEGAS, NEW MEXICO, 8 Appellee-Respondent.

9 APPEAL FROM THE DISTRICT COURT OF SAN MIGUEL COUNTY 10 Abigail Aragon, District Judge

11 Youtz & Valdez, P.C. 12 Shane Youtz 13 Stephen Curtice 14 James A. Montalbano 15 Albuquerque, NM

16 for Appellant

17 Holcomb Law Office 18 Dina E. Holcomb 19 Albuquerque, NM

20 for Appellee 21 MEMORANDUM OPINION

1 HANISEE, Judge. 2 {1} The American Federation of State, County and Municipal Employees, 3 Council 18, AFSCME Local 2851 (AFSCME) appeals from the district court’s 4 order upholding the administrative decision of the City of Las Vegas Labor 5 Management Relations Board1 (the Board), which dismissed AFSCME’s petition 6 seeking to accrete, or add, certain employees of the City of Las Vegas (the City) 7 into the existing “blue and white collar bargaining unit.” AFSCME argues, inter 8 alia, that the district court erred in determining that “the record supports the 9 [Board’s] decision.” We conclude that the record as presently constituted does not 10 support the Board’s decision and, therefore, reverse and remand for further 11 proceedings consistent with this opinion.2 12 BACKGROUND 13 {2} AFSCME filed a “Petition for Clarification (Accretion)” (AFSCME’s 14 petition) with the Board seeking to accrete various positions into an existing 15 bargaining unit covering City employees. While all of the positions included 16 “supervisor” as part of the job title, AFSCME asserted that the employees

1

The Board and the City were both named as defendants in AFSCME’s appeal to the district court, but the Board was dismissed as a party on its unopposed motion on August 1, 2016.

2

Because we reverse on this basis, we do not reach AFSCME’s arguments that the Board (1) violated the Open Meetings Act, NMSA 1978, §§ 10-15-1 to -4 (1974, as amended through 2013), by voting on AFSCME’s petition in closed session, and (2) improperly assigned the burden of proof to AFSCME.

1 occupying the positions were not themselves “supervisors” as that term is defined 2 under the Public Employees Bargain Act (PEBA), NMSA 1978, §§ 10-7E-1 to -26 3 (2003, as amended through 2005). On March 10, 2015, the Board held an all-day 4 hearing (merits hearing), at which employees then holding the positions at issue 5 testified, as did some of their subordinates, AFSCME officials, and managerial 6 representatives from the City. In addition to taking witness testimony, the Board 7 received for its consideration numerous exhibits submitted by the parties, as well 8 as a post-hearing brief from each party. 9 {3} On April 27, 2015, the Board met to consider AFSCME’s petition. When it 10 convened, the Board’s chairman called the meeting to order and stated, “[W]e 11 haven’t had a chance . . . to get together and go over the information” related to 12 AFSCME’s petition and that “[w]hat we’d like to do is call into executive session 13 for . . . at least 15 minutes before we actually start the meeting.” After an 14 unspecified period of time, the chairman returned and announced, “[W]e are out of 15 executive session[,]” explained that the board members had considered all of the 16 information before them, and proceeded to allow another board member “go 17 through the decisions” of the Board. That board member explained that the Board 18 had “considered a number of factors . . . includ[ing] the definition of supervisor . . . 19 [and] the relevant arguments that have been presented both in the briefs and the 20 attached case law.” He further explained that “one of the things that we keyed off

1 on was the definition of federal law in regards to exercising independent 2 judgment,” which he described as “one of the overriding principles for all the 3 positions that we’re going to be discussing.” As to each of the five individuals 4 whose position the petition sought to accrete into the unit, the Board summarily 5 concluded that “[AFSCME] ha[d] not met its burden of proof to accrete.” For only 6 one of the individuals, Benito Lujan, did the Board identify specific evidence—the 7 testimony of one employee supervised by Lujan that “she had been told by Mr. 8 Lujan that he would write her up if she did certain things”—to support its denial of 9 the petition to accrete. The Board issued an oral ruling denying AFSCME’s 10 petition and excluding the five positions from the bargaining unit. 11 {4} Nearly five months later, on September 10, 2015, the Board issued a two- 12 page order, titled “Order Dismissing Clarification Petition.” The order contains 13 neither a discussion of the evidence nor findings of fact to support the Board’s 14 decision and provides no explanation of the Board’s ruling, despite the governing 15 Board rule requiring that it file a report within fifteen days following the close of a 16 hearing in which it makes findings of fact and conclusions of law and “adequately 17 explain[s] the Board’s reasoning.” City of Las Vegas, Labor/Mgmt. Relations Bd., 18 Rules & Regulations, § II, Rule 2.13. Instead, the order merely states that the 19 Board found that AFSCME “has not met its burden of proof to accrete the 20 position[s] into the bargaining unit.”

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