Chelsea v. New England Police Benevolent Association, Inc., Local 192

CourtMassachusetts Supreme Judicial Court
DecidedMarch 8, 2023
DocketSJC 13331
StatusPublished

This text of Chelsea v. New England Police Benevolent Association, Inc., Local 192 (Chelsea v. New England Police Benevolent Association, Inc., Local 192) is published on Counsel Stack Legal Research, covering Massachusetts Supreme Judicial Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Chelsea v. New England Police Benevolent Association, Inc., Local 192, (Mass. 2023).

Opinion

NOTICE: All slip opinions and orders are subject to formal revision and are superseded by the advance sheets and bound volumes of the Official Reports. If you find a typographical error or other formal error, please notify the Reporter of Decisions, Supreme Judicial Court, John Adams Courthouse, 1 Pemberton Square, Suite 2500, Boston, MA, 02108-1750; (617) 557- 1030; SJCReporter@sjc.state.ma.us

SJC-13331

CITY OF CHELSEA vs. NEW ENGLAND POLICE BENEVOLENT ASSOCIATION, INC., LOCAL 192.

Suffolk. January 6, 2023. - March 8, 2023.

Present: Budd, C.J., Gaziano, Lowy, Cypher, Kafker, Wendlandt, & Georges, JJ.

Arbitration, Arbitrable question, Confirmation of award. Public Employment, Collective bargaining, Termination. Labor, Collective bargaining, Grievance procedure, Public employment, Arbitration.

Civil action commenced in the Superior Court Department on July 26, 2021.

The case was heard by Patrick M. Haggan, J., on motions for judgment on the pleadings.

The Supreme Judicial Court on its own initiative transferred the case from the Appeals Court.

Strephon Treadway for the plaintiff. Thomas E. Horgan for the defendant.

KAFKER, J. After the New England Police Benevolent

Association, Inc., Local 192 (NEPBA), replaced the International

Brotherhood of Teamsters, Local 25 (Local 25), as the exclusive 2

bargaining representative for the emergency dispatchers in the

city of Chelsea (city), the NEPBA sought to arbitrate a

grievance regarding the termination of a dispatcher that

occurred following the change in union representation. The

NEPBA and the city had not yet bargained to a new contract, but

employees had been working pursuant to the terms and conditions

of the city's prior collective bargaining agreement with Local

25, which contained an arbitration provision. The parties

submitted to an arbitrator the question whether the dispute was

arbitrable. The arbitrator ruled that it was. The city now

appeals from a Superior Court order confirming the arbitrator's

decision.

We determine that the dispute was arbitrable because (1)

the dispute clearly would have been covered by the broad

arbitration provision negotiated by the city and the prior

union, if the contract with the city had remained in effect; (2)

the arbitrator, acting within her authority, found that the

contract was extended by the city according to the terms of the

contract, and we defer to such contractual interpretation by the

arbitrator; and (3) we conclude that the labor relations act

entitles a successor union to "step[] into the shoes of its

predecessor" and enforce an arbitration provision in a

collective bargaining agreement negotiated by its predecessor. 3

See Watertown v. Watertown Mun. Employees Ass'n, 63 Mass. App.

Ct. 285, 291 (2005) (Watertown).

Background. The city's emergency dispatchers had been

represented by Local 25 since 2009. On January 3, 2020, the

NEPBA filed a petition to represent the bargaining unit. On

January 8, 2020, Local 25 sent a letter disclaiming interest in

representing the dispatchers. The NEPBA won the subsequent

election unanimously; due to Local 25's disclaimer, it was the

only union on the ballot. On April 16, 2020, the Department of

Labor Relations certified the NEPBA as the dispatchers'

exclusive representative.

The most recent collective bargaining agreement in effect

for the dispatchers was negotiated by Local 25. It contained

multiple arbitration provisions. One stated that "[o]nly

matters involving questions whether the [c]ity is complying with

its obligations under this [a]greement, including matters

involving the meaning, application or interpretation of the

[a]greement" are subject to the grievance and arbitration

procedure, except that "[n]o matter shall be subject to the

arbitration procedure of this [a]greement which is subject to

the authority or jurisdiction of Civil Service or any Retirement

Board." More specifically, the agreement also provided: "Any

protest against discipline, suspension or discharge shall be 4

handled under the grievance and arbitration procedure provided

for in the agreement."

By its terms, the agreement also had the following

duration:

"This [a]greement shall remain in full force and effect from July 1, 2016 until midnight June 30, 2019 and shall terminate unless extended by mutual consent of the parties, or unless either party hereto gives written notice to the other not less than sixty (60) days prior to the date of expiration, of a desire to change or amend the terms or conditions hereof."

The city solicitor wrote to representatives of Local 25 on

January 31, 2019 (thus "not less" than sixty days before June

30): "Our agreements expire on June 30, 2019 and I was hoping

to schedule our initial meetings for bargaining." Although

Local 25 and the city exchanged proposals for a new contract and

met several times, they did not reach an agreement. A

representative from the NEPBA reached out to start contract

negotiations after the union was certified, but by the time of

the dispute in question, the parties had not reached an

agreement. The city continued to abide by all provisions in the

contract during this period of time and apparently has done so

to this day, with the exception of the arbitration provision.

Nearly one year after the NEPBA was certified, a dispatcher

allegedly failed to properly dispatch a fire response, and then

misreported the facts in a subsequent investigation. As a

result, the city dismissed her. The union protested the 5

discipline and invoked the grievance procedure in the collective

bargaining agreement, which involves a multistep process that

culminates in arbitration. The relevant contract term states:

"Grievances not settled in the [s]teps of the grievance procedure may be referred to an arbitrator agreed upon by the parties . . . [or one] designated by the American Arbitration Association . . . . The decision of the arbitrator within the scope of his authority shall be final and binding upon the parties."

Although the city disputed that it was required to

arbitrate the grievance, the parties proceeded to arbitration

and submitted to the arbitrator the question whether the dispute

was arbitrable. The arbitrator ruled that it was, because the

agreement negotiated by Local 25 was still in effect on February

1, 2021, by its terms. The arbitrator explained: "While [the]

letter [regarding scheduling bargaining] does not use the exact

language of Article 25 [(the duration provision)], I find that

it adequately satisfies Article 25, and thus extended that

contract." She also relied on the reasoning of the Appeals

Court decision in Watertown discussing the presumption of

arbitrability, including when "the arbitration provision being

interpreted involves expiring contracts and changes in union

representation." Watertown, 63 Mass. App. Ct. at 290.

The city filed a complaint in the Superior Court to vacate

the arbitration award, arguing that the arbitrator exceeded her

authority because there was no agreement to arbitrate in effect 6

once Local 25 disclaimed interest. See G. L. c. 150C, § 11 (a)

("the superior court shall vacate an award if . . . the

arbitrators exceeded their powers"). The union moved to confirm

the arbitration award.

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