City of Erie v. Fraternal Order of Police

57 Pa. D. & C.2d 779, 1971 Pa. Dist. & Cnty. Dec. LEXIS 86
CourtPennsylvania Court of Common Pleas, Erie County
DecidedSeptember 30, 1971
Docketno. 70 of 1971
StatusPublished
Cited by1 cases

This text of 57 Pa. D. & C.2d 779 (City of Erie v. Fraternal Order of Police) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Erie County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
City of Erie v. Fraternal Order of Police, 57 Pa. D. & C.2d 779, 1971 Pa. Dist. & Cnty. Dec. LEXIS 86 (Pa. Super. Ct. 1971).

Opinion

MCCLELLAND, J.,

— By agreement of counsel, I am authorized to write an opinion instead of the usual equity findings of fact, conclusions of law, decree nisi, et cetera.

The parties are before the court relative to a petition seeking to disqualify the appointment of John Harrington as an arbitrator because he is President of the National Fraternal Order of Police, of which defendant lodge is a member.

Under an act of assembly, collective bargaining by policemen is permitted and, upon reaching an impasse at the bargaining table, a board of arbitration may be appointed.

The statute, Act of June 24, 1968, 43 PS §217.1, provides that:

“The board of arbitration shall be composed of three persons, one appointed by the public employer, one appointed by the body of policemen or firemen involved, and a third member to be agreed upon by the public employer and such policemen or firemen.”

“The determination of the majority of the board of arbitration thus established shall be final on the issue or issues in dispute and shall be binding upon the public employer and the policemen or firemen involved”: 43 PS §§217.4 and 217.7, quotations in part.

An annotation in 65 A. L. R., 2nd, 755-7, addresses itself to this subject saying:

“Since arbitrators are selected, not as agents of the parties, but to act in a quasi-judicial capacity in place of a court, they must ordinarily be impartial and nonpartisan so as to render exact justice to the parties. Anyone unable, by reason of interest or bias, to act impartially in the proceedings and to render a fair and just award, is ineligible to the office. An interest or bias to disqualify may be small, but it must be direct, definite, and capable of demonstration, [781]*781not remote, uncertain, or speculative. A person is disqualified to act as an arbitrator if he is himself a party to the dispute, and may be disqualified if he is a close relative, servant, employee, or agent of one of the parties, or has any secret interest in the result or decision of the dispute.
“Arbitration statutes generally provide for vacating an award on grounds of interest, bias, or fraud of an arbitrator, but are silent as to a remedy in advance of an award.
“. . . Accordingly, it has generally been held in actions arising under arbitration statutes that the court has no power to intervene until after an award has been made by the arbitrators, although a contrary result has been reached where intervention has been sought under the general equity powers of a court.
“. . . In actions which invoked the general equity powers of a court, it has been held that an arbitrator may be removed for bias or prejudice, and that the arbitration proceedings may be stayed or suspended until a new arbitrator has been appointed.”

The requisite impartiality required of arbitrators has been best summarized in 5 Am. J. 2d, pp. 595, 596, as follows:

“If parties are to be encouraged to arbitrate, arbitration proceedings must be conducted with the same degree of impartiality as the courts afford. Public policy requires, therefore, that arbitrators not only be completely impartial but also that they have no connection with the parties or the dispute involved which might give the appearance of their being otherwise. Obviously a person is disqualified to act as an arbitrator if he is himself a party to the dispute. And, in the ordinary case, a close relative, servant, employee, or agent of one of the parties to [782]*782the controversy, or one who has any secret interest in the result or decision thereof, may not properly act as an arbitrator. An arbitrator is legally disqualified to act if he has a pecuniary interest in the relief sought, if this fact is not known to the party adversely affected. And a corporate officer may not act if his corporation has a pecuniary interest in the outcome of the arbitration and this interest is unknown to one of the parties.
“Mere personal friendship with one of the parties is no disqualification, nor is the fact that the person named as arbitrator has been counsel in previous litigation, has frequently acted in a similar capacity in like cases for others or for the party appointing him, or is a creditor of one of the parties. And the mere fact that there is some business relationship between the arbitrator and one of the parties to the arbitration is not in and of itself sufficient to disqualify the arbitrator. But although, as a matter of law, the relations above mentioned do not automatically, or as a matter of law, disqualify a person as an arbitrator, in a proper case they may be examined in connection with other circumstances on the question of fraud or misconduct and in determining as a matter of fact whether he is a disinterested or impartial arbitrator ...”

To the same effect, see 6 C. J. S., Arbitration and Award, §46.

A leading case in Pennsylvania is Munson v. Dury Clothing, 33 D. & C. 2d 450 (1964). President Judge Pinola, of Luzerne County wrote the opinion. The Munson case stands for the proposition that an officer and shareholder of a corporation who participated upon behalf of the corporation in discussions involving a controversy is not qualified to act [783]*783as an arbitrator in a proceeding to resolve the controversy.

Among other things, Judge Pinola said:

“The judicial mind is so strongly against the propriety of allowing one of the parties, or its special representative to be judge or arbitrator in its own case, that even a strained interpretation will be resorted to if necessary to avoid that result: Kelly v. Trimont Lodge, 154 N. C. 97, 69 S.E. 764.” See Munson Case, page 452.

Hanley v. City of Bradford, 50 D. & C. 2d 152 (1970), relies upon Munson and ruled the City Manager of Bradford ineligible to sit as an arbitrator in a dispute involving said City of Bradford.

However, the Chester County court refused to disqualify the client of a party’s attorney as an arbitrator: Kent v. Tripodi, 13 Chester Co. R. 124 (1965).

In this particular case, the City of Erie relies upon the older view that each member of an arbitration panel .must be completely neutral and impartial. The older view is heavenly in concept but rather unrealistic in practice. Obviously, in a tripartite arbitration selection such as the city and police used here, each side is attempting to obtain an arbitrator who will, at least, listen to its point of view in a friendly fashion. I am not proclaiming that the arbitrator selected by the city or police would be anyone but a splendid person. I am suggesting that, realistically speaking, the arbitrator might think, feel and act a bit like the people who selected him.

Frankly, when each arbitrator can select a third and obviously neutral arbitrator, I see nothing terribly wrong with this procedure.

Recent cases “recognize that in a tripartite arrangement, where each party to a dispute is given the [784]*784right to select an arbitrator and the third member is selected by them or by a disinterested party, the arbitrator selected by the disputants cannot be expected to play a wholly impartial part. They are partisans once removed from the actual controversy . . See opinion of Judge Dawson in Stef Shipping Corp. v. Norris Grain Co., 209 F.Supp. 249, 253 (1962).

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Related

Borough of New Cumberland v. Police Employees
439 A.2d 849 (Commonwealth Court of Pennsylvania, 1981)

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Bluebook (online)
57 Pa. D. & C.2d 779, 1971 Pa. Dist. & Cnty. Dec. LEXIS 86, Counsel Stack Legal Research, https://law.counselstack.com/opinion/city-of-erie-v-fraternal-order-of-police-pactcomplerie-1971.