Professional Fire Fighters of Eastern Missouri, International Association of Fire Fighters, Local 2665 v. City of Richmond Heights

CourtMissouri Court of Appeals
DecidedNovember 28, 2023
DocketWD86174
StatusPublished

This text of Professional Fire Fighters of Eastern Missouri, International Association of Fire Fighters, Local 2665 v. City of Richmond Heights (Professional Fire Fighters of Eastern Missouri, International Association of Fire Fighters, Local 2665 v. City of Richmond Heights) is published on Counsel Stack Legal Research, covering Missouri Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Professional Fire Fighters of Eastern Missouri, International Association of Fire Fighters, Local 2665 v. City of Richmond Heights, (Mo. Ct. App. 2023).

Opinion

IN THE MISSOURI COURT OF APPEALS WESTERN DISTRICT PROFESSIONAL FIRE FIGHTERS ) OF EASTERN MISSOURI, ) INTERNATIONAL ASSOCIATION ) OF FIRE FIGHTERS, LOCAL 2665, ) ) Appellant, ) ) v. ) WD86174 ) CITY OF RICHMOND HEIGHTS, ) Opinion filed: November 28, 2023 ) ) Respondent. )

APPEAL FROM THE CIRCUIT COURT OF COLE COUNTY, MISSOURI THE HONORABLE S. COTTON WALKER, JUDGE

Division One: Edward R. Ardini, Jr., Presiding Judge, Anthony Rex Gabbert, Judge and Janet Sutton, Judge

Professional Fire Fighters of Eastern Missouri, International Association of Fire

Fighters, Local 2665 (the “Local”) appeals the judgment of the Circuit Court of Cole

County, affirming a decision of the State Board of Mediation (the “Board”). The Local

filed a Petition for Certification of Representation with the Board, seeking to create a

bargaining unit consisting of fire captains employed by the City of Richmond Heights (the

“City”) and to be certified as that unit’s bargaining representative. The City filed a motion to dismiss the Local’s petition. The Board granted the City’s motion and dismissed the

petition pursuant to the “contract bar rule.” The Local sought judicial review of the Board’s

dismissal of its Petition for Certification of Representation in the Circuit Court of Cole

County (the “trial court”). The trial court affirmed the decision of the Board. We find the

Board’s decision was arbitrary and unreasonable, and thus we reverse the trial court’s

judgment.

Factual and Procedural Background

There exists between the Local and the City a Memorandum of Understanding

(“MOU”) providing that the Local is the exclusive bargaining representative of all full-

time employees of the City’s fire department, excluding “Captains, Battalion Chiefs, and

Fire Chief.” Beginning in September 2020, the Local and the City engaged in collective

bargaining negotiations to modify the existing MOU, which resulted in the City rejecting

several proposals by the Local to include captains in the bargaining unit. The Local then

turned to the Board in its efforts.

“The State Board of Mediation is a quasi-judicial board created by section 295.030

to oversee labor disputes arising between parties subject to Chapter 295 (which generally

relates to ‘labor relations affecting public utilities’).” St. Louis Police Officer’s Ass’n v. St.

Louis Cty., 670 S.W.3d 86, 88 n.1 (Mo. App. E.D. 2023). “Several other Missouri statutes

have ‘borrowed’ the Board for their purposes,” including—as relevant to this appeal—

section 105.525, which is part of Missouri’s public sector labor law. Id. Section 105.525

2 provides that “[i]ssues with respect to appropriateness of bargaining units and majority

representative status shall be resolved by the state board of mediation.”1

In October 2021, the Local filed a Petition for Unit Clarification with the Board,

seeking to expand the certified bargaining unit of fire department employees to include

captains. The Board dismissed the Local’s petition without prejudice pursuant to the

“contract bar rule.” The Board’s contract bar rule provides that “petitions to the State Board

of Mediation are untimely if the bargaining unit subject to the petition is covered by an

active labor agreement, unless the petition is filed no earlier than 90 days and not later than

61 days before the termination of the agreement.” Prof’l Fire Fighters of E. Mo., IAFF

Local 2655 v. City of Hazelwood, Public Case No. UC 2014-007, 2014 WL 12767422, at

*3 (Mo. State Bd. of Mediation Dec. 23, 2014).2 In dismissing the Local’s petition, the

Board explained that “a valid agreement exists between [the City’s] Fire Department and

[the Local],” “[t]he term of the agreement is for a year period which is in effect until April

1 In 2018, the General Assembly enacted HB 1413, which repealed almost all sections of Missouri’s public sector labor law and created twenty-one new sections. St. Louis Cty., 670 S.W.3d at 91. However, HB 1413 was subsequently struck down by the Missouri Supreme Court on equal protection grounds. See Mo. Nat’l Educ. Ass’n v. Mo. Dep’t of Labor & Indus. Relations, 623 S.W.3d 585, 592-93 (Mo. banc 2021). The Court “not only struck HB 1413 from the books, but the public sector labor law, sections 105.500-105.530, reverted to its pre-HB 1413 iteration.” St. Louis Cty., 670 S.W.3d at 91. Accordingly, all references to sections 105.500 to 105.530 are to the 2016 version of these statutes. 2 The contract bar doctrine is also applied by the National Labor Relations Board, with the purpose of “promot[ing] industrial peace by stabilizing, for a reasonable term, a contractual relationship between employer and union.” NLRB v. F & A Food Sales, Inc., 202 F.3d 1258, 1261 (10th Cir. 2000). Similarly, the Board’s stated purpose of applying the contract bar rule is to “balance[] the competing interests of the employees’ freedom of choice in selecting a bargaining representative and the stability of collective bargaining agreements between an employer and the employees’ elected union.” City of Hazelwood, 2014 WL 12767422, at *3-4. 3 21, 2022,” and that “being the case, the agreement acts as a bar to any election until the

‘open window’ period which is January 22, 2022 to February 20, 2022.”

On January 17, 2022, the Local again filed a Petition for Unit Clarification with the

Board, seeking to expand the certified bargaining unit to include captains. The Board again

dismissed the petition without prejudice pursuant to the contract bar rule, as the “open

window” period did not begin until January 22nd.

On February 11, 2022—within the “open window” period—the Local re-filed its

Petition for Unit Clarification. This time the Board dismissed the petition with prejudice

on the grounds that the petition violated the “Wallace-Murray Rule, which prohibits adding

previously excluded employees to the unit without an election.”3

Counsel for the Local e-mailed the chairman of the Board, asking what type of

petition the Local should file to request an election to include captains in the existing

bargaining unit:

The Board’s website only lists four types of Petitions which may be filed, and none of those Petitions appear to fit squarely into the current situation. The closest arguably applicable Petition would be the Petition for Certification of Representation. Before our office files this Petition, we wanted to seek confirmation from you that this is the Petition the Board is asking to be filed in order for an election to be conducted to include Captain’s [sic] in the existing bargaining unit. If this is not the proper Petition, please advise.

3 “The NLRB first announced this limitation on unit clarification in Wallace-Murray Corp., 192 NLRB 1090 (1971), and has adhered to the rule since.” NLRB v. Miss. Power & Light Co., 769 F.2d 276, 279 (5th Cir. 1985) (describing the rule as preventing employees from being “added by unit clarification . . . where they intentionally and historically were excluded from the existing bargaining unit” (internal emphasis omitted)). 4 The chairman responded, “You are correct; a Petition of Certification of

Representation is proper. Should the election be successful, we could then merge the two

units with a Unit Clarification Petition.”

On March 10, 2022, the Local filed a Petition for Certification of Representation

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Professional Fire Fighters of Eastern Missouri, International Association of Fire Fighters, Local 2665 v. City of Richmond Heights, Counsel Stack Legal Research, https://law.counselstack.com/opinion/professional-fire-fighters-of-eastern-missouri-international-association-moctapp-2023.