SEPTA v. Transport Workers Union of America, Local 234

17 Pa. D. & C.5th 526
CourtPennsylvania Court of Common Pleas, Philadelphia County
DecidedOctober 22, 2010
Docketno. 1851
StatusPublished

This text of 17 Pa. D. & C.5th 526 (SEPTA v. Transport Workers Union of America, Local 234) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Philadelphia County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
SEPTA v. Transport Workers Union of America, Local 234, 17 Pa. D. & C.5th 526 (Pa. Super. Ct. 2010).

Opinion

PANEPINTO, J.,

— Petitioner, Southeastern Pennsylvania Transportation Authority (“SEPTA”), appeals this court’s order dated July 22, 2010, denying petitioner’s motion to Vacate an arbitration award.

PROCEDURAL AND FACTUAL BACKGROUND

This matter stems from an April 9, 2010 arbitration award by Arbitrator Walter De Treux in a labor arbitration between SEPTA and Transport Workers Union of America, Local 234 (“Union”). SEPTA sought to [528]*528discharge Gilbert Stringfield (“Stringfield”), a SEPTA bus operator since October 2001, after an encounter with Shanique Scott (“Scott”), a SEPTA maintenance custodian. Stringfield and Scott were in a romantic relationship at the time of the incident. On July 21, 2007, Scott was at Stringfield’s residence. Stringfield wanted to have sexual relations with Scott. Scott, however, declined Stringfield’s requests. Stringfield then became physically violent with Scott and forced himself on her. Scott called her mother to report what had happened after Scott had left the room. Scott’s mother called the police, who arrived at Stringfield’s residence and arrested him (See Arbitrator’s Award p.l). Scott obtained a restraining order against Stringfield, barring him from having any contact with Scott whatsoever. Scott does not contend that Stringfield violated the order (See Ar. Award p. 10).

Stringfield was formally charged with multiple crimes including: sexual assault (F2), indecent assault forcible compulsion (Ml), simple assault (M2), rape forcible compulsion (FI), recklessly endangering another person (M2), and aggravated assault (F2) (See formal charges, Ex. C, motion to vacate).

In addition to these charges, SEPTA also brought Bus Operations Rules and Regulations Manuals charges against Stringfield for personal conduct, assaulting an employee, and violation of law. The union requested the charges for personal conduct and assaulting an employee be dismissed, and the charge for violation of law held in abeyance pending the outcome of the criminal matter. SEPTA honored this request, dropped two of the charges and removed them from Stringfield’s performance record [529]*529(See October 10, 2007 letter to President of Local 234, Ex. E, motion to vacate). Stringfield was placed in a maintenance custodian position during this time, pending resolution of the criminal charges against Stringfield.

Stringfield agreed to a plea deal in which the felony charges for sexual assault, rape forcible compulsion, and aggravated assault were nolle prossed and he pleaded guilty to indecent assault forceible compulsion, simple assault, and recklessly endangering another person (See disposition and dismissal, Ex. C, motion to vacate). Stringfield pleaded guilty to the misdemeanors only and the felony charges were nolle prossed. (See June 23, 2009 order, Ex. C, motion to vacate). Defendant was sentenced to three (3) years probation, restitution, and counseling. (See September 4, 2009 order, Ex. C, motion to vacate).

On June 26, 2009, SEPTA made known its intention to discharge Stringfield under section 20 ID of the collective bargaining agreement (“CBA”). A formal hearing occurred on September 24, 2009, after which Stringfield was discharged. SEPTA made this determination because of this provision; “a. An employee who is convicted of any criminal offense which was committed when the employee was not in an employment status, i.e. not committed while on duty...may be discharged when: (2) the employee’s conviction relates to the employee’s suitability for continued employment in the position then held” (See SEPTA Policy Instruction, Ex. J, motion to vacate). This requires a showing that there is a nexus between the continued employment and his duties and responsibilities as a bus driver. SEPTA admitted that a violation of law does not require an automatic discharge [530]*530but rather is determined under the facts of the case. (See Arb. Award p.5). SEPTA determined that Stringfield’s criminal convictions related to his suitability for continued employment as a SEPTA bus driver because of the nature of his crimes and that Stringfield works unsupervised with the public as a bus driver.

The union filed a grievance on October 2, 2009. There was a labor relations step hearing on October 15, 2009. SEPTA upheld the discharge as it found that the crimes committed were directly related to Stringfield’s position as a bus operator and raised concern for the safety and well being of the riding public (See Labor Relations Step Hearing Report, Ex. I, motion to vacate).

Arbitration soon followed. Scott testified that reinstatement of Stringfield would make her feel uncomfortable and unsafe. The arbitration award was issued on April 9,2010. The arbitrator did find Stringfield’s actions against Scott to be egregious and offensive. However, he ordered that Stringfield be reinstated with back pay for reasons more fully discussed in the discussion section below. In short, the arbitrator did not find a nexus between the crimes committed and Stringfield’s suitability for work (See Arb. Award p. 10).

ALLEGATIONS OF ERROR

On August 25, 2010, this court entered an order directing defendant to file a Rule 1925(b) statement no later than twenty (20) days after the entry of the order. Defendant filed a rule 1925(b) statement pursuant to this court’s order on September 14,2010. Defendant has raised the following issues on appeal:

[531]*5311. The court erred in refusing to vacate the arbitration award on the basis that the award violates Pennsylvania’s well-defined, dominant public policy in favor of protecting the interests of victims of crime and ensuring that such victims are treated with dignity and respect.
2. The court erred in refusing to vacate the arbitration award on the basis that the award violates Pennsylvania’s well-defined, dominant public policy requiring public transportation systems to provide for the safe transportation of the riding public.
3. The court erred in refusing to vacate the arbitration award on the basis that the award violates Pennsylvania’s well-defined, dominant public policy promoting workplace safety and imposing a duty on employers to provide a safe workplace.
4. The court erred in refusing to vacate the arbitration award on the basis that the award violates Pennsylvania’s well-defined, dominant public policies against sexual harassment in the workplace and in favor of voluntary employer prevention and remediation of workplace sexual harassment.
5. The court erred in refusing to vacate the arbitration award on the grounds that the award is not rationally derived from nor does it have a foundation in the collective bargaining agreement (“CBA”) and, therefore, does not draw its essence from the CBA.

DISCUSSION

Where, as here, a labor arbitration award is challenged on the basis that the award exceeds the power of the [532]*532arbitrator, the Pennsylvania Supreme Court has adopted the “essence test” as the standard of judicial review which states that an arbitration award is legitimate “so long as it draws its essence from the collective bargaining agreement.” See State Sys. Of Higher Educ. (Cheyney Univ.) v. State Coll. Univ. Prof 1 Ass’n (PSEA/NEA), 560 Pa. 135,

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17 Pa. D. & C.5th 526, Counsel Stack Legal Research, https://law.counselstack.com/opinion/septa-v-transport-workers-union-of-america-local-234-pactcomplphilad-2010.