In the Matter of Officer Gregory DiGuglielmo and New Jersey Institute of Technology

CourtSupreme Court of New Jersey
DecidedNovember 28, 2022
DocketA-33-21
StatusPublished

This text of In the Matter of Officer Gregory DiGuglielmo and New Jersey Institute of Technology (In the Matter of Officer Gregory DiGuglielmo and New Jersey Institute of Technology) is published on Counsel Stack Legal Research, covering Supreme Court of New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In the Matter of Officer Gregory DiGuglielmo and New Jersey Institute of Technology, (N.J. 2022).

Opinion

SYLLABUS

This syllabus is not part of the Court’s opinion. It has been prepared by the Office of the Clerk for the convenience of the reader. It has been neither reviewed nor approved by the Court and may not summarize all portions of the opinion.

In the Matter of Officer Gregory DiGuglielmo & New Jersey Institute of Technology (A-33-21) (085064)

Argued September 28, 2022 -- Decided November 28, 2022

PIERRE-LOUIS, J., writing for a unanimous Court.

Here the Court determines whether a particular form of arbitration is available to police officers at public colleges and universities when appealing a suspension or termination. Specifically, the Court considers whether New Jersey Institute of Technology (NJIT) Officer Gregory DiGuglielmo, who was suspended with pay and then terminated from his position, is ineligible to challenge his termination through special disciplinary arbitration pursuant to N.J.S.A. 40A:14-210 either because he was not a municipal police officer or because he was suspended with pay.

After pursuing and using physical force to restrain a juvenile bicyclist, Officer DiGuglielmo was placed on leave with pay and then terminated. He filed a challenge to his termination with the New Jersey Public Employment Relations Commission (PERC), requesting “special disciplinary arbitration” pursuant to N.J.S.A. 40A:14-210. NJIT objected, claiming that appeal forum is only for municipal police in non-civil service jurisdictions. PERC held Officer DiGuglielmo was eligible for special disciplinary arbitration and appointed an arbitrator.

The Appellate Division reversed, holding that special disciplinary arbitration was available only to municipal officers because N.J.S.A. 40A:14-209 and -210 incorporate by reference the terms and limitations found in N.J.S.A. 40A:14-150, which only applies to municipal officers not subject to civil service. 465 N.J. Super. 42, 46, 61 (App. Div. 2020). The court further held that, even if special disciplinary arbitration was available to campus police officers, Officer DiGuglielmo was nevertheless ineligible because he was not suspended without pay. Id. at 63. The Court granted certification. 249 N.J. 94 (2021).

HELD: A plain reading of the relevant statutes dictates that special disciplinary arbitration is not limited to municipal officers, so arbitration is available to public university police officers like Officer DiGuglielmo. Further, pursuant to N.J.S.A. 40A:14-210, an officer suspended with pay prior to termination is eligible to engage in special disciplinary arbitration. The Court therefore reinstates PERC’s decision.

1 1. N.J.S.A. 40A:14-150 governs the review of disciplinary action in non-civil service municipalities. Prior to 2009, Section 150 only provided disciplined members of a police force in a non-civil service municipality the right of independent judicial review in Superior Court. In 2009, in a series of amendments designed to enhance the rights of certain disciplined police officers and firefighters, the Legislature created special disciplinary arbitration as an alternative procedure to the judicial appeals process for municipal officers and as a new forum of appeal for certain other non-civil service officers. Section 150 is housed within Subchapter D of Title 40A’s Chapter 14. Subchapter D governs the creation, regulation, powers, and duties of municipal police departments and officers. Section 150 cross- references N.J.S.A. 40A:14-209 in describing the new avenue of appeal available to municipal officers. Section 209 is part of the group of provisions housed in Subchapter J -- a subchapter newly created in 2009 and separate from Subchapter D. Special disciplinary arbitration, the focus of this appeal, is described in N.J.S.A. 40A:14-209 and -210, and the Court reviews those sections in detail. (pp. 12-15)

2. Section 209 applies when an officer is “suspended from performing . . . official duties without pay” and confers a right to be paid wages after a period of time while awaiting the completion of the special arbitration process. Section 209 cross- references Section 150 in distinguishing between special disciplinary arbitration and the judicial review that has always been available to non-civil service municipal officers. Section 209 also cross-references N.J.S.A. 40A:14-210 in noting that special disciplinary arbitration must comply with the provisions of Section 210, which details the procedures to be followed for seeking and conducting special disciplinary arbitration. Section 210 cross-references both Sections 150 and 209. Once again, the reference to Section 150 distinguishes between the new arbitration procedure and municipal officers’ right to appeal to the Superior Court. The cross- reference to Section 209 is limited to a recognition that officers seeking to challenge their suspension or termination via special disciplinary arbitration are not eligible for that form of appeal if their disciplinary matter is related to a criminal offense. Section 200, the first section of the new Subchapter J, is a definitional section that includes the terms “law enforcement agency” and “law enforcement officer.” The Court reviews those definitions, which emphasize the broad range of officers that the Legislature sought to make eligible for special disciplinary arbitration. (pp. 15-18)

3. The Court considers whether Section 150 precludes NJIT police officers like Officer DiGuglielmo from appealing adverse employment determinations through special disciplinary arbitration, as the Appellate Division held, particularly given the cross-reference to Section 150 in Sections 209 and 210. Section 150 applies solely to non-civil service municipal officers. But a close reading of Sections 209 and 210 reveals that, although both reference Section 150, those references have nothing to do with who is eligible for special disciplinary arbitration pursuant to the new amendments. There is nothing in the plain language of Sections 209 and 210 that 2 mentions municipal officers or indicates that Sections 209 and 210, which are housed in a different subchapter than Section 150, were intended to apply only to municipal officers. (pp. 18-20)

4. The statutory cross-references in the 2009 amendments are plentiful, but every cross-reference must be carefully read to determine the purpose for which the other statute is being addressed. It is not necessarily the case that when a statute is cross- referenced by another statute it is for the purpose of wholesale importation of the referenced statute into the other. A plain reading of Sections 209 and 210 does not indicate that the Legislature intended the references to Section 150 to limit special disciplinary arbitration to municipal officers. Indeed, had the Legislature intended for special disciplinary arbitration to apply only to non-civil service municipal officers, the new statutory provisions would likely have been inserted into Subchapter D, which governs municipal police officers, rather than in Subchapter J. And the definitions set forth in Section 200, which apply to the provisions of Subchapter J and thus to Sections 209 and 210, undoubtedly broaden the category of officers to whom special disciplinary arbitration is available beyond only municipal officers. The Court’s conclusion that special disciplinary arbitration is available to NJIT officers is consistent with PERC’s interpretation of special disciplinary arbitration eligibility and the manner in which PERC has administered this form of arbitration since the enactment of the 2009 amendments. (pp. 20-23)

5. The Appellate Division further held that special disciplinary arbitration is not available to Officer DiGuglielmo because he was suspended with pay and the court did not “read Section 210 to nullify the eligibility requirement of suspension- without-pay repeatedly stated within Section 209.” 465 N.J. Super.

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In the Matter of Officer Gregory DiGuglielmo and New Jersey Institute of Technology, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-matter-of-officer-gregory-diguglielmo-and-new-jersey-institute-of-nj-2022.