In the Matter of the Reallocation of the Probation Officer And

119 A.3d 921, 441 N.J. Super. 434
CourtNew Jersey Superior Court Appellate Division
DecidedJuly 22, 2015
DocketA-0056-13T2
StatusPublished
Cited by15 cases

This text of 119 A.3d 921 (In the Matter of the Reallocation of the Probation Officer And) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division 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 the Reallocation of the Probation Officer And, 119 A.3d 921, 441 N.J. Super. 434 (N.J. Ct. App. 2015).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-0056-13T2

IN THE MATTER OF THE REALLOCATION OF THE PROBATION OFFICER AND APPROVED FOR PUBLICATION PROBATION OFFICER, BILINGUAL IN July 22, 2015 SPANISH AND ENGLISH TITLES FROM THE COMPETITIVE TO THE NON- APPELLATE DIVISION COMPETITIVE DIVISION OF THE CAREER SERVICE. ____________________________________

Argued April 22, 2015 – Decided July 22, 2015

Before Judges Alvarez, Waugh, and Carroll.

On appeal from the New Jersey Civil Service Commission, Docket No. 2013-3251.

Lynsey A. Stehling argued the cause for appellant Probation Association of New Jersey (Law Offices of Daniel J. Zirrith LLC, attorneys; Daniel J. Zirrith, of counsel; Ms. Stehling, on the brief).

Todd A. Wigder, Deputy Attorney General, argued the cause for respondent New Jersey Civil Service Commission (John J. Hoffman, Acting Attorney General, attorney; Lewis A. Scheindlin, Assistant Attorney General, of counsel; Mr. Wigder, on the brief).

The opinion of the court was delivered by

WAUGH, J.A.D.

The Probation Association of New Jersey (Association)

appeals the final administrative agency decision of the New

Jersey Civil Service Commission (Commission) concerning the manner in which the Administrative Office of the Courts (AOC)

selects and appoints candidates for the titles of Probation

Officer and Probation Officer, Bilingual in Spanish and English

(Bilingual Probation Officer). We reverse and remand for

further consideration consistent with this opinion.

I.

We discern the following facts and procedural history from

the record on appeal.

On December 5, 2011, pursuant to N.J.A.C. 4A:1-4.3, the AOC

requested the Commission to establish a one-year pilot program

to replace competitive testing for the Probation Officer and

Bilingual Probation Officer titles with an evaluation system.1

The AOC explained that the pilot program was necessary because

"at least four vicinages [had] exhausted [their] current pool

and several others [were] close to exhausting their pools" for

the Bilingual Probation Officer title. The AOC made no such

factual assertion with respect to the Probation Officer title.

The proposed program would replace the traditional system

of competitive testing that is generally used throughout the

State government with an evaluation program designed to focus on

1 The AOC also sought to replace the four-month working test period provided by N.J.A.C. 4A:4-5.2(b)(2) with a Probation Officer Trainee title that would provide a full year of training and evaluation, but subsequently withdrew that request.

2 A-0056-13T2 a candidate's communication skills, personal motivation,

interpersonal skills, analytical skills, reasoning ability,

personal development, and time management skills. Candidates'

credentials would be reviewed and scored based on education and

work experience. The cover letters and resumes would be

evaluated and rated based on the number of errors in spelling,

grammar, and punctuation. Candidates with the highest scoring

resumes would be selected for a structured panel interview, be

required to complete a timed writing sample, and be evaluated

for promptness and neatness. Successful candidates would return

for a second structured interview, after which selected

finalists would receive offers of employment. The program would

be administered by vicinage or a regional group of vicinages, as

appropriate. The AOC's Division of Equal Employment

Opportunity/Affirmative Action would review the candidate pools

for diversity, and preference for veterans would be taken into

consideration.

The purpose of the proposed system was to allow for "a more

flexible process for recruitment and selection than the

traditional civil service testing process provides." The AOC

was particularly interested in oral examinations, which it

believed to be "a critical element of the selection process" and

which the Commission would not be able to administer because of

3 A-0056-13T2 the large number of candidates. In addition, the AOC explained

that "the flexibility of the proposed pilot program would allow

vicinages the opportunity to proactively recruit before their

candidate pool is empty," whereas the Commission only

administers its examinations at set intervals.

The proposal was opposed by the Association, which

submitted opposition to the Commission. The Association argued

that the proposal violated article VII, section 1, paragraph 2

of the New Jersey Constitution, which requires public employees

to be selected on the basis of "merit and fitness to be

ascertained, as far as practicable, by examination, which, as

far as practicable, shall be competitive." It further argued

that the AOC had not established sufficient need for the change

and that past instances of noncompetitive hiring had not been

successful. Finally, the Association called for a fact-finding

hearing in the Office of Administrative Law (OAL). The

Association subsequently argued that any problem caused when

hiring pools run low could be solved by interim, noncompetitive

appointments pursuant to N.J.A.C. 4A:3-1.2.

On June 21, following further submissions by the parties

and the AOC's acceptance of modifications suggested by the

Commission's staff, the Commission issued a final administrative

4 A-0056-13T2 order approving the pilot program.2 The year-long pilot program

was originally to have been implemented on July 1, 2012, but the

Commission subsequently delayed the implementation date to

November 1 at the AOC's request.

In its decision, the Commission concluded that the program

was consistent with N.J.A.C. 4A:3-1.2(c)(2), which allows a job

title to be placed "in the noncompetitive division on an ongoing

or interim basis" if the Commission determines "that it is

appropriate to make permanent appointments to the title and . .

. [c]ertification procedures based on ranked eligible lists have

not or are not likely to meet the needs of appointing

authorities due to such factors as salary, geographic location,

recruitment problems, and working conditions." It explained:

In this regard, the AOC has indicated that it has experienced problems maintaining a sufficient pool of qualified and interested candidates in all geographic locations during the duration of eligible lists resulting from competitive testing. Indeed, one of the primary goals of the pilot program is to address this difficulty by providing the [AOC] with a way in which to continuously recruit qualified applicants . . . with announcements directed to particular regions of the State on an as- needed basis.

2 The Association appealed that decision. That appeal was dismissed as moot after the Commission approved use of the noncompetitive process on an ongoing basis.

5 A-0056-13T2 The Commission found that the program would involve

"structured recruitment and selection," which would focus on

"six broad-based competencies for successful performance in the

. . . titles," namely, communication, personal motivation,

interpersonal skills, analysis and reasoning, self-development,

and time management. "The competencies and assigned weights

[were] consistent with a job analysis performed by the Division

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