Madison County Board of Commissioners and Madison County Highway Department v. American Federation of State County and Municipal Employees Local 3609 (mem. dec.)

CourtIndiana Court of Appeals
DecidedApril 19, 2017
Docket33A01-1609-PL-2136
StatusPublished

This text of Madison County Board of Commissioners and Madison County Highway Department v. American Federation of State County and Municipal Employees Local 3609 (mem. dec.) (Madison County Board of Commissioners and Madison County Highway Department v. American Federation of State County and Municipal Employees Local 3609 (mem. dec.)) is published on Counsel Stack Legal Research, covering Indiana Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Madison County Board of Commissioners and Madison County Highway Department v. American Federation of State County and Municipal Employees Local 3609 (mem. dec.), (Ind. Ct. App. 2017).

Opinion

MEMORANDUM DECISION Pursuant to Ind. Appellate Rule 65(D), this FILED Memorandum Decision shall not be regarded as Apr 19 2017, 8:35 am precedent or cited before any court except for the CLERK purpose of establishing the defense of res judicata, Indiana Supreme Court Court of Appeals collateral estoppel, or the law of the case. and Tax Court

ATTORNEYS FOR APPELLANTS ATTORNEYS FOR APPELLEE Jeffrey K. Graham William R. Groth Micha R. Buffington David T. Vink Graham, Regnier, Farrar & Wilson, P.C. Indianapolis, Indiana Elwood, Indiana

IN THE COURT OF APPEALS OF INDIANA

Madison County Board of April 19, 2017 Commissioners and Madison Court of Appeals Case No. County Highway Department, 33A01-1609-PL-2136 Appeal from the Henry Circuit Appellants-Defendants, Court. The Honorable Jack Tandy, Senior v. Judge. Cause No. 33C01-1502-PL-8 American Federation of State County and Municipal Employees Local 3609, Appellee-Plaintiff.

Friedlander, Senior Judge

[1] Madison County appeals the trial court’s award of attorney’s fees. To place the

present appeal and our decision in proper context, the following is a summary

of the underlying facts and procedural history of this case derived from our

Court of Appeals of Indiana | Memorandum Decision 33A01-1609-PL-2136 | April 19, 2017 Page 1 of 17 opinion in the first appeal involving these parties, reported in Madison County

Board of Commissioners v. American Federation of State County and Municipal

Employees Local 3609, 45 N.E.3d 868 (Ind. Ct. App. 2015), trans. denied, and

from the material presented here on appeal.

[2] Scott Amos, president of the American Federation of State County and

Municipal Employees Local 3609 (the Union), and Travis Benfield, vice-

president of the Union, were employed by the Madison County Highway

Department (the Department) as truck drivers. On June 23 through June 25 of

2014, they were assigned to the same truck to repair potholes and broken

pavement.

[3] On June 23rd and 24th, a county commissioner observed the truck to which

Amos and Benfield were assigned idling for some time on the road near his

house. The commissioner observed that some, but not all, of the road had been

repaired before the employees left the location at the end of both days. Each

day the county commissioner reported his observations to the Department

superintendent; however, neither Amos nor Benfield were notified or warned of

the complaints/allegations. On June 25th, the GPS tracking device on the truck

used by Amos and Benfield indicated, and another Department employee

observed, that the truck used by the two was parked near two restaurants for

over an hour. Under the Collective Bargaining Agreement (CBA) entered into

by the County and the Union, Department employees are allowed a half hour

at mid-day without pay to eat lunch. Appellants’ App. Vol. II, p. 52.

Court of Appeals of Indiana | Memorandum Decision 33A01-1609-PL-2136 | April 19, 2017 Page 2 of 17 [4] When Amos and Benfield returned the truck to the Department garage on June

25th, they were given “Disciplinary Notice Written Warnings dated Monday,

June 23, 2014,” stating that they were being disciplined for a Class B 5 minor

infraction occurring on June 23, 2014 for sleeping on the job or loafing, or

spending excessive time at lunch. 45 N.E.3d at 871; Appellants’ App. Vol. II,

p. 59 (defining Class B minor infractions and discipline), and p. 67. On June

26, 2014, Amos and Benfield were suspended without pay pending an

investigation into their alleged violations of the CBA, county personnel policies,

and Indiana employment statutes. The allegations supporting their suspension

contended Amos and Benfield were guilty of ghost employment for failure to

perform their duties while on the job. Appellants’ App. Vol. II, p. 67.

[5] The CBA between the Union and the County recognized the County’s

authority to take appropriate disciplinary action for just cause. Id. at 69-70.

Under the CBA, employees may be disciplined for class A minor infractions,

class B minor infractions, or major infractions of work rules. A class B

infraction includes sleeping on the job, loafing or spending excessive time at

lunch periods, and other actions deemed class B infractions by the Department

superintendent. Id. p. 59. In unusual situations, class B infractions may be

elevated to a major infraction. Major infractions include: theft or dishonesty of

any kind; using County property or equipment for personal matters not required

by job duties; falsification, tampering with, removing, or misusing any County

records, documents, or reports; leaving the job during working hours without

Court of Appeals of Indiana | Memorandum Decision 33A01-1609-PL-2136 | April 19, 2017 Page 3 of 17 prior authorization; and, other actions of similar consequences deemed so by

the Department superintendent. Id. at 60.

[6] A first violation classified as a class B infraction offense results in a written

warning, the second offense results in a five-day layoff without pay, and the

third offense results in the employee being subject to discharge. Id. at 59. On

the other hand, the commission of a single major infraction results in the

employee being subject to discharge. Id. at 60-61. Disciplinary action, if any,

shall take place within three working days from the time the incident was

reported to the Department superintendent or the designee. Id. at 58-59.

[7] After a pre-deprivation hearing, held per the terms of the CBA, Amos and

Benfield were notified that their employment was terminated immediately due

to findings that they had committed ghost employment by submitting timecards

representing that they were working, where the evidence showed they were not.

Id. at 67-68. The notice further stated that they had committed major

infractions, which subjected them to discharge and that the matter was being

referred to the prosecutor’s office. Id. at 68. The major infractions found were

those examples mentioned above.

[8] Amos and Benfield utilized the CBA’s grievance procedures and the matter was

submitted to arbitration. According to the CBA, “[t]he arbitrator shall have no

authority to add to, change, delete, or otherwise modify any part of this

agreement. Any decision of the arbitrator shall be final and binding on all

parties.” 45 N.E.3d at 872. The question that was stipulated to by the parties

Court of Appeals of Indiana | Memorandum Decision 33A01-1609-PL-2136 | April 19, 2017 Page 4 of 17 and presented to the arbitrator was, “Were the discharges of [the Employees]

for just cause? If not, what is the proper remedy?” Id.; Appellants’ App. Vol.

II, p. 68.

[9] The arbitrator issued an award finding that the County had failed to prove that

Amos and Benfield had engaged in ghost employment. The arbitrator also

found that Amos’ and Benfield’s actions did not fall within the categories of

major infractions. Instead, the arbitrator found that the employees had

committed the misconduct set forth in the initial written warnings—sleeping or

loafing on the job and taking an excessively long lunch break—which were

identified as class B minor infractions in the written warning delivered to Amos

and Benfield. The arbitrator adjusted the sanction of immediate termination,

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Madison County Board of Commissioners and Madison County Highway Department v. American Federation of State County and Municipal Employees Local 3609 (mem. dec.), Counsel Stack Legal Research, https://law.counselstack.com/opinion/madison-county-board-of-commissioners-and-madison-county-highway-department-indctapp-2017.