National Federation of Federal Employees v. Federal Labor Relations Authority

789 F.2d 944, 252 U.S. App. D.C. 262, 122 L.R.R.M. (BNA) 2244, 1986 U.S. App. LEXIS 24698
CourtCourt of Appeals for the D.C. Circuit
DecidedMay 2, 1986
Docket85-1260
StatusPublished
Cited by5 cases

This text of 789 F.2d 944 (National Federation of Federal Employees v. Federal Labor Relations Authority) is published on Counsel Stack Legal Research, covering Court of Appeals for the D.C. Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
National Federation of Federal Employees v. Federal Labor Relations Authority, 789 F.2d 944, 252 U.S. App. D.C. 262, 122 L.R.R.M. (BNA) 2244, 1986 U.S. App. LEXIS 24698 (D.C. Cir. 1986).

Opinions

MIKVA, Circuit Judge:

The National Federation of Federal Employees (NFFE) petitions for review of the Federal Labor Relations Authority’s dismissal of a complaint alleging an unfair labor practice. Because we find that the Authority improperly ordered dismissal without addressing the issues presented in the complaint, we reverse the order of dismissal and remand to the Authority for further proceedings.

I. FINALITY AND LEGALITY: THE BALANCE REACHED IN THE FEDERAL SERVICE LABOR-MANAGEMENT RELATIONS ACT

The Federal Service Labor-Management Relations Act (Labor-Management Act or the Act), 5 U.S.C. §§ 7101-35 (1982), governs collective bargaining between federal civilian employees and management. See generally American Federation of Government Employees v. Federal Labor Relations Authority, 778 F.2d 850, 851-52 (D.C.Cir.1985) (AFGE). The Labor-Management Act confers collective bargaining rights upon employees. The Act also provides for the involvement of the Federal Service Impasses Panel (the Panel) in settling bargaining impasses. When a bargaining impasse arises between the parties, either party may request the Panel to conduct an inquiry. If the parties are unable to reach a settlement after the Panel has made initial recommendations, the Panel is empowered to hold hearings, take testimony, and “take whatever action is necessary and not inconsistent with this chapter to resolve the impasse.” 5 U.S.C. § 7119(c)(5)(B)(i)-(iii). In the interest of finality, the Panel is authorized to impose contract terms on the parties. These imposed terms become “binding on such parties during the term of the agreement, unless the parties agree otherwise.” § 7119(c)(5)(C).

The Act, however, establishes a tension between the Panel’s power to impose a binding provision on the parties and the statutory right of an agency head to review the provision. After the Panel has acted, the resulting agreement between the agency and its employees’ exclusive representative is subject to approval by the head of the agency. § 7114(c)(1). The Labor-Management Act directs the agency head to approve che agreement within thirty days from the date the agreement is executed “if the agreement is in accordance with the provisions of this chapter and any other applicable law, rule, or regulation (unless the agency has granted an exception to the provision).” § 7114(c)(2).

An agency head’s disapproval of an agreement is “essentially an assertion of nonnegotiability.” AFGE, 778 F.2d at 853. Under the Labor-Management Act, assertions of nonnegotiability, including the agency head’s disapproval, afford the union the right to review. § 7117(c)(2). The statute also provides criteria to determine whether the matter is indeed negotiable. For example, an employer has no duty to bargain in good faith on a matter to the extent that it is “inconsistent with any Federal law or any Government-wide rule or regulation.” § 7117(a)(1). If the bargaining proposal is consistent with these external authorities, but is covered by an agency rule or regulation, it is negotiable only if the Authority finds that there is no compelling need for the agency’s rule or regulation. § 7117(a)(2). The exclusive bargaining agent thus places negotiability in issue when it alleges, inter alia, either that the rule or regulation asserted by the agency as a bar to negotiations violates applicable law, or rule or regulation of appropriate authority outside the agency; or that no compelling need exists for the rule or regulation to bar negotiations on the matter. See 5 C.F.R. § 2424.1 (1985).

[946]*946Thus, if the Authority determines that an Impasses Panel’s provision was neither contrary to applicable external law nor contrary to an agency rule for which there is a compelling need, the agency head will have refused to negotiate on a negotiable issue. In the context of a Panel provision, the refusal will also have constituted failure to cooperate with impasse decisions. These two actions implicate the statute’s prohibitions on unfair labor practices. The Act provides:

§ 7116(a) For the purpose of this chapter, it shall be an unfair labor practice for an agency—
(1) to interfere with, restrain, or coerce any employee in the exercise by the employee of any right under this chapter;
(5) to refuse to consult or negotiate in good faith with a labor organization as required by this chapter;
(6) to fail or refuse to cooperate in impasse procedures and impasse decisions as required by this chapter.

II. The FLRA’s Decision

This dispute arises out of collective bargaining between the U.S. Army Electronics Research and Development Command (ER-ADCOM) at Fort Monmouth, New Jersey, and NFFE Local 476, the exclusive bargaining representative for ERADCOM’s civilian employees. The parties reached an impasse on issues relating to the procedures for performance appraisal of employees. The union proposed extending the period of advance notice — from 30 days to 60 days — that the agency must afford an employee before denying that employee a within-grade increase. Specifically, the proposal required ERADCOM to notify employees that they could avoid this result by improving performance to an acceptable level within sixty days. ERADCOM did not agree to this proposal, and the resulting impasse was submitted to the Panel pursuant to section 7119 of the Labor-Management Act.

The Panel deliberated and ordered ER-ADCOM to accept the union’s proposal. Department of the Army, U.S. Army Electronics Research and Development Command, Fort Monmouth, New Jersey and Local 476, NFFE, 82 FSIP 78 (Oct. 29, 1982). In accordance with the Panel’s order, ERADCOM and the union added the union’s proposal to their collective bargaining agreement in December 1982.

In January 1983, ERADCOM’s parent command, the United States Army Materiel Development and Readiness Command (DARCOM), rejected the sixty-day notice provision. DARCOM declared the notice provision contrary to law or regulation, and therefore not subject to negotiation. Reviewing the provision as an agency head under section 7114, DARCOM asserted that the sixty-day provision conflicted with its existing regulation, which implemented the statutory minimum of thirty days’ notice for employees against whom adverse action is proposed. See 5 U.S.C. § 4303(b)(1)(A). While the statute authorizes the agency to promulgate regulations extending this period for an additional thirty days, § 4303(b)(2), the Army has not drafted any such extension.

Petitioner filed an unfair labor practices charge based on the agency head’s refusal to implement the Panel provision. The charge alleged that viewed in light of the government’s failure to allege nonnegotia-bility prior to the Panel decision, its refusal to implement the Panel’s decision, and its bargaining in bad faith, the agency head’s disapproval of the Panel’s provision violated subsections 7116(a)(1), (a)(5), and (a)(6).

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789 F.2d 944, 252 U.S. App. D.C. 262, 122 L.R.R.M. (BNA) 2244, 1986 U.S. App. LEXIS 24698, Counsel Stack Legal Research, https://law.counselstack.com/opinion/national-federation-of-federal-employees-v-federal-labor-relations-cadc-1986.