LAS VEGAS POLICE PROTECTIVE ASSOC. v. CITY OF LAS VEGAS (CIVIL)

CourtNevada Supreme Court
DecidedJune 3, 2026
Docket89985
StatusPublished

This text of LAS VEGAS POLICE PROTECTIVE ASSOC. v. CITY OF LAS VEGAS (CIVIL) (LAS VEGAS POLICE PROTECTIVE ASSOC. v. CITY OF LAS VEGAS (CIVIL)) is published on Counsel Stack Legal Research, covering Nevada Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
LAS VEGAS POLICE PROTECTIVE ASSOC. v. CITY OF LAS VEGAS (CIVIL), (Neb. 2026).

Opinion

142 Nev., Advance Opinion L-A

IN THE SUPREME COURT OF THE STATE OF NEVADA

LAS VEGAS POLICE PROTECTIVE No. 89985 ASSOCIATION, A NEVADA NONPROFIT CORPORATION, Appellant, F LE3 vs. JUN 03 2026 - CITY OF LAS VEGAS, A LOCAL GOVERNMENT EMPLOYER, Respondent.

Appeal from a district court order granting a motion for summary judgment in a dispute over the interpretation of arbitration and longevity pay provisi.ons of a collective bargaining agreement. Eighth Judicial District Court, Clark County; Ronald J. Israel. Reversed an,d remanded.

Sgro & Roger and Anthony P. Sgro and Manna Bondy, Las Vegas, for Appellant.

Jeffry M. Dorocak, City Attorney, and Nechole Garcia, Chief Deputy City Attorney, Las Vegas, for Respondent.

BEFORE THE SUPREME COURT, STIGLICH, CADISH, and LEE, JJ.

OPINION

By the Court, STIGLICH, J.: Nevada law generally recognizes a division of labor between

SUPREME C OURT courts and arbitrators in adjudicating arbitration agreements. Absent OF NEVADA

2k- 24912 contractual provisi.ons providing otherwise, district courts determine whether a particular dispute is arbitrable; that is, whether it falls within the scope of the arbitration provision. Beyond that threshold question, the arbitrator evaluates whether procedural. prerequisites have been satisfied, chooses the format of arbitration proceedings, and adjudicates the underlying issue. In this case, the district court determined that the City of Las Vegas, one of two parties to a collective bargaining agreement (CBA) containing an arbitration provision, was entitled to dictate the arbitration format and unilaterally determine whether a procedural prerequisite to arbitration had been satisfied. As the CBA did not contain a provision

assigning the format and procedural prerequisite determinations, these matters were reserved by default for the arbitrator. Accordingly, we conclude the district court erred in finding the City was permitted to unilaterally settle these matters. Moreover, because the arbitrability of the dispute is not in question, we conclude the district court erred in ruling on the merits of the longevity pay issue. For these reasons, we reverse the district court's grant of summary judgment and remand for further proceedings consistent with this opinion. FACTS AND PROCEDURAL HISTORY Between 2006 and 2025, appellant Las Vegas Police Protective Association (LVPPA) executed various CBAs with respondent, the City of Las Vegas, on behalf of municipal court and deputy city marshals. Relevantly, each CBA provided for longevity pay—additional compensation based on the number of years employed by the City. The longevity pay formula accounted for annual increases to base salaries. In 201.9, several marshals alleged that the City was miscalculating longevity pay. The CBA in effect at that time provided for a

SUPREME COURT four-step grievance procedure to address disputes out of court arising from OF NEVADA

, 2 the "application or interpretation" of CBA terms. The first step was to "file a grievance with Human Resources within 30 calendar days of the knowledge of the grievance." Second, the grievant would meet with the Department Director. If the issue remained unresolved, the third step was

for the Department Director to respond in writing. At that point, if the grievant wished to further pursue the matter, the fourth and final step was to request arbitration. Pursuant to these provisions, the marshals submitted a joint grievance alleging that the City had underpaid longevity pay since 2013. The matter apparently proceeded to the arbitration stage, but the City asserted that the grievance was untimely and insisted on a bifurcated arbitration format by which the timeliness of the grievance would be determined before addressing the merits of the longevity pay issue. After the arbitration was scheduled, other LVPPA members filed additional grievances alleging the same issue, which the City rejected as untimely. Before any arbitration occurred, LVPPA filed two complaints for declaratory relief with the district court. The first complaint echoed the LVPPA members' filed grievances, asking the court to declare that the City was underpaying longevity pay and to direct the City to pay LVPPA mernbers "longevity pay consistent with the terms of the current [CBA]" and backpay totaling more than $350,000 to correct previous miscalculated longevity pay. The second complaint alleged a distinct breach of the CBA by the City for insisting on a bifurcated two-stage arbitration for the initial grievance and rejecting the subsequent grievances. In that second complaint, LVPPA requested the district court to order the City to comply with the CBA's arbitration provision, arguing that the timeliness of

SUPREME COURT OF NEVADA

3 grievances is itself a "grievabie issue" to be ultimately determined by an arbitrator. Thereafter, the parties agreed to consolidate the actions and the City then moved for summary judgment. The district court granted the City's motion, agreeing with its interpretation of the longevity pay and

grievance provisions. LVPPA appeals. DISCUSSION "We review a district court order granting summary judgment

de novo, viewing all evidence in a light most favorable to the nonmoving party." Boesiger v. Desert Appraisals, LLC, 1.35 Nev. 192, 194, 444 P.3d 436, 439 (2019). Summary judgment is appropriate when "there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law." NRCP 56(a). The di.strict court erred in finding that the City was permitted to unilaterally reject grievances as untimely and insist on a two-stage arbitration format The parties agree that the CBA in effect at the time the grievances were filed provides the "comprehensive and exclusive procedure" for resolving grievances, which ends with arbitration. LVPPA argues that the CBA does not permit the City to seize the arbitrator's role and impose a bifurcated arbitration process or unilaterally reject grievances as untimely. The City argues that the grievances were "ineligible to proceed to arbitration" because the CBA required grievances to be filed within 30 days of discovering the basis for the grievance and those at issue were filed six years after the first alleged underpaymen.t. The City maintains that, although it agreed to arbitrate the initial grievance under a bifurcated procedure, it is not required to arbitrate that or the subsequent grievances. As noted, the CBA provides that the initial step in the dispute resolution process i.s to "file a grievance with Human Resources within 30 SUPREME COURT OF NEVADA

4 calendar days of the knowledge of the grievance." Under these terms, the district court found the grievances were untimely because the alleged underpayment was, or should have been, discovered in 2016 and the grievances were not filed until three years later, well after the 30-day CBA filing deadline. Consequently, the court found the City had no obligation to process or arbitrate the grievances and was entitled to insist on a bifurcated proceeding on the initial grievance and refuse to arbitrate the subsequent grievances. We discern two problems with the district court's ruling. First,

the CBA does not authorize the City to unilaterally deem the grievances untimely and thereby inarbitrable. Second, the City was not entitled to insist on a two-stage bifurcated arbitration process. We address each of

these issues in turn.

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LAS VEGAS POLICE PROTECTIVE ASSOC. v. CITY OF LAS VEGAS (CIVIL), Counsel Stack Legal Research, https://law.counselstack.com/opinion/las-vegas-police-protective-assoc-v-city-of-las-vegas-civil-nev-2026.