CITY OF NEWTON v. COMMONWEALTH EMPLOYMENT RELATIONS BOARD & another.

100 Mass. App. Ct. 574
CourtMassachusetts Appeals Court
DecidedDecember 30, 2021
StatusPublished
Cited by3 cases

This text of 100 Mass. App. Ct. 574 (CITY OF NEWTON v. COMMONWEALTH EMPLOYMENT RELATIONS BOARD & another.) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
CITY OF NEWTON v. COMMONWEALTH EMPLOYMENT RELATIONS BOARD & another., 100 Mass. App. Ct. 574 (Mass. Ct. App. 2021).

Opinion

NEWTON vs. COMMONWEALTH EMPLOYMENT RELATIONS BOARD, 100 Mass. App. Ct. 574

CITY OF NEWTON vs. COMMONWEALTH EMPLOYMENT RELATIONS BOARD & another. [Note 1]

100 Mass. App. Ct. 574

September 1, 2021 - December 30, 2021

Court Below: Commonwealth Employment Relations Board

Present: Green, C.J., Singh, & Hand, JJ.

Police, Collective bargaining. Public Employment, Police, Collective bargaining, Psychiatric examination. Labor, Public employment, Collective bargaining, Duty to bargain, Police. Municipal Corporations, Police, Collective bargaining. Waiver. Commonwealth Employment Relations Board.

The Commonwealth Employment Relations Board (board) did not err in concluding that a city was required to engage in impact bargaining upon demand over the criteria and procedures for fitness for duty examinations of a police officer and violated G. L. c. 150E, § 10 (a) (5), and, derivatively, § 10 (a) (1), in failing to do so, where, given that the examination results had a direct impact on job security and the city's managerial decisions with respect to employment, the methods and means by which the examinations were conducted were mandatory subjects of bargaining; where the criteria the union sought to bargain (i.e., the process of requesting the examinations, the procedures for administering them, and the subsequent use of information obtained in the course of them) were distinct from the city's order for the examinations themselves; where the city's interest in public safety was not undercut by the requirement that it engage in impact bargaining with the union over the procedures and criteria for the fitness for duty examinations; and where the interplay between the provisions of G. L. c. 150E and the civil service law, G. L. c. 31, § 61A, did not relieve the city of its duty to bargain the terms and impact of the fitness for duty examinations [578-584]; further, the board correctly concluded that the union did not waive its right to negotiate the means and impact of the fitness for duty examination requirement, where neither an article of the collective bargaining agreement (agreement) pertaining to an annual physical examination by a specified examiner nor an article of the agreement containing a broadly framed management rights clause provided a basis for inferring a clear and unmistakable waiver by the union of mandatory bargaining over the manner and means of fitness for duty examinations [584-585], and where the union did not waive by inaction its right to negotiate the means and impact of the fitness for duty examination requirement, given that the union did not have actual knowledge of the city's actions in the absence of any mutually known and agreed-upon past practice of sending officers for examination or for unilaterally imposing

Page 575

the procedure related to the examinations, and given that the union had no actual notice that the examinations were being performed in reliance on the police department's code of conduct or a city ordinance that empowered the city to order fitness for duty examinations [585-587].


APPEAL from a decision of the Commonwealth Employment Relations Board.

Jeffrey A. Honig, Deputy City Solicitor, for city of Newton.

Jillian M. Bertrand for Commonwealth Employment Relations Board.

Alan H. Shapiro (John M. Becker also present) for Newton Police Superior Officers Association, MassCOP Local 401.


HAND, J. In 2016, the chief of police (chief) of the city of Newton (city), in consultation with the city's employment manager, ordered Captain Doe [Note 2] to undergo physical and psychological "fitness for duty" examinations, and placed him on paid administrative leave pending the results of those examinations. The Newton Police Superior Officers Association, MassCOP Local 401 (union) -- of which Doe was a bargaining unit member and which had a collective bargaining agreement with the city (CBA) -- requested bargaining over certain aspects of the examinations. The city did not bargain as requested by the union. After undergoing both examinations, Doe was cleared to return to work. The union filed a charge of prohibited practice with the Department of Labor Relations (DLR) alleging, inter alia, that the city had engaged in practices in violation of G. L. c. 150E, § 10 (a) (5), and derivatively, § 10 (a) (1), [Note 3] when it (1) failed to bargain over the procedure for fitness for duty examinations and (2) imposed a fitness for duty policy as a condition of employment without first giving the union notice and an opportunity to bargain to resolution or impasse about the decision and its impact on employees' terms and conditions of employment. [Note 4]

A hearing officer of the DLR, and on the city's appeal from the DLR decision, the Commonwealth Employment Relations Board

Page 576

(board), concluded that the city failed to meet its obligation to engage in impact bargaining over the criteria and procedure for the fitness for duty examinations to which Doe was required to submit as a condition of his continued employment -- including, specifically, the selection of the examiner, the information to be transmitted to the examiner, the testing protocol to be used by the examiner, the results to be generated by the examiner, and to whom the results of the examinations were to be communicated -- and "when it imposed the fitness for duty policy as a condition of [Doe's] continued employment without providing notice and an opportunity to bargain to resolution or impasse about the decision and [its] impacts . . . on employees' terms and conditions of employment." [Note 5] The board also rejected the city's argument that the union had waived its right to bargain over these issues. We affirm.

Background. We summarize the undisputed facts as found by the board, supplementing with additional undisputed facts in the record as needed. In 2016, the chief noted that Doe had recently taken an unusually high number of personal days following recent deaths in his family and a personal injury not related to his work, and the chief believed that Doe "seemed to be a different person than he had been." [Note 6] Citing these reasons, on September 27, 2016, the chief presented Doe with a letter that placed him on paid administrative leave pending the results of physical and psychological fitness for duty examinations. The physical examination was to take place that day, and the letter informed Doe that the city's human resources department would shortly advise him of the date of the appointment for the psychological examination. Following receipt of the letter, Doe requested union representation.

During a meeting at which the chief, Doe, and Doe's union

Page 577

representative were present, the chief stated that he had "just cause" under the city police department's "Code of Conduct [and] Appearance" (code of conduct) to order Doe to undergo the examinations, citing, in addition, his authority to order the examinations under city ordinance § 2-46(c). [Note 7], [Note 8] The result of the meeting was an agreement that Doe would comply with the order. Doe attended the physical examination, provided samples for drug testing, and submitted to a breathalyzer test. Later that day, Doe was cleared by the first examiner to return to work pending the results of the drug test. Doe ultimately passed all drug and alcohol tests.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
100 Mass. App. Ct. 574, Counsel Stack Legal Research, https://law.counselstack.com/opinion/city-of-newton-v-commonwealth-employment-relations-board-another-massappct-2021.