State of New Jersey, Etc. v. Policemen's Benevolent Association, Local 105

CourtNew Jersey Superior Court Appellate Division
DecidedJanuary 16, 2025
DocketA-1091-23
StatusUnpublished

This text of State of New Jersey, Etc. v. Policemen's Benevolent Association, Local 105 (State of New Jersey, Etc. v. Policemen's Benevolent Association, Local 105) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of New Jersey, Etc. v. Policemen's Benevolent Association, Local 105, (N.J. Ct. App. 2025).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-1091-23

STATE OF NEW JERSEY, GOVERNOR'S OFFICE OF EMPLOYEE RELATIONS (DEPARTMENT OF CORRECTIONS, JUVENILE JUSTICE COMMISSION, and STATE PAROLE BOARD),

Plaintiff-Respondent,

v.

POLICEMEN'S BENEVOLENT ASSOCIATION, LOCAL 105,

Defendant-Appellant. ___________________________

Argued November 19, 2024 – Decided January 16, 2025

Before Judges Gilson and Bishop-Thompson.

On appeal from the Superior Court of New Jersey, Law Division, Mercer County, Docket No. L-1887-23.

Donald C. Barbati argued the cause for appellant (Crivelli, Barbati & DeRose, LLC, attorneys; Donald C. Barbati, on the brief). Ryne A. Spengler, Deputy Attorney General, argued the cause for respondent (Matthew J. Platkin, Attorney General, attorney; Donna Arons, Assistant Attorney General, of counsel; Ryne A. Spengler, on the brief).

PER CURIAM

This appeal arises from a grievance between the State of New Jersey

(State) and the Policemen's Benevolent Association 105 (PBA 105), which

represents various police and corrections officers within the State. The dispute

concerns the payment of the uniform allowance commingled with wages in a

regular bi-weekly payday to eligible employees and not in a supplemental

payday. PBA 105 appeals from a Law Division order granting the State's

application to vacate the arbitration award and reasoning the award was procured

by undue means and a mistake of fact. We hold the arbitration award was

reasonably debatable based on the contract language and past practice. We,

therefore, reverse, vacate the trial court's order, and reinstate the arbitration

award.

I.

We derive the following facts from the record. PBA 105 is the sole and

exclusive representative for police officers, and other related job titles employed

by the State. The prior collective negotiations agreement (CNA) expired on

June 30, 2019.

A-1091-23 2 The parties engaged in negotiations on a successor CNA. On April 20,

2021, the parties signed a memorandum of agreement (MOA) for a successor

agreement that commenced on July 1, 2019, and terminated on June 30, 2023

(2019 CNA). Article XXXVIII – Uniform Allowance governs the allowance

payment. That section provided that each affected employee entitled to the

uniform allowance payment shall receive such payment in January and July of

each calendar year. Regarding State Parole Board officers, that article stated:

No allowance will be paid to employees who are not required to purchase a uniform and wear it for work. Accordingly, as of ratification of this Agreement, unit members working in Parole are not eligible for a uniform allowance. In the event Parole employees are required to wear uniforms for work during any portion of any year for the term of this Agreement, the State agrees to a uniform maintenance allowance for the affected employees as follows:

*** • Should employees be required to wear a uniform anytime between January 1, 2022 and June 30, 2022, each employee shall receive $920.00 in July 2022. Only those employees with at least one (1) year of service as of June 30, 2022 shall be entitled to this payment;

In a separate paragraph, the article specified the uniform allowance for

Department of Corrections (DOC) and Juvenile Justice Corrections officers:

Employees who are required to wear or own a uniform for work and who are serving in the titles of

A-1091-23 3 Correctional Police Officer Recruit, Senior Correctional Police Officer, Correctional Police Officer Recruit, Juvenile Justice, Senior Correctional Police Officer, Juvenile Justice, and Senior Interstate Escort Officer will be granted, in lieu of any uniform allowances other than the initial issues, the following payments:

***

• $1,100.00 in July 2022 to those employees with at least one (1) year of service as of June 30, 2022[.]

The State paid the July 2022 uniform allowance on August 5, 2022 (Pay

Period 16), in the officers bi-weekly payday rather than in the supplemental

payday in July that was a longstanding sixteen-year past practice. Due to the

uniform allowance's inclusion in the bi-weekly payday, additional state taxes

were withheld compared to the taxes that would have been withheld if the

allowance was paid as a supplement.

The State denied PBA 105's grievance, which proceeded to binding

arbitration. The Public Employment Relations Commission appointed an

arbitrator to hear and decide the disputed issue.

A grievance arbitration was held on February 24, 2023. The parties agreed

that after hearing all the evidence and arguments, the arbitrator framed the issue

A-1091-23 4 as — "Whether the State violated Article XXXVIII of the parties' [CNA] and

past practice, and if so, what shall be the remedy?"

Both parties presented witnesses and documents at the arbitration. PBA

105 presented the testimony of Union President William Sullivan, then a

seventeen-year DOC corrections police officer who had been "involved" in

contract negotiations with the State since 2016. According to Sullivan for the

past sixteen years, the State had issued uniform allowance payments on

supplemental paydays rather than on regular, bi-weekly paydays. He further

testified that based on research of his own payment history, the State made all

but two uniform allowance payments on supplemental paydays each year.

In 2022, PBA 105 members received the July 2022 uniform allowance on

Pay Period 16, a regular, bi-weekly payday, which was not agreed upon by the

parties in the 2019 CNA. That payment was unlike the agreement reached with

the State permitting payment on January 25, 2019, a regular, bi-weekly payday

because the State was in the process of calculating retroactive pay for employees

following the settlement of a successor CNA.

Richard Corcoran, CPA, employed with the accounting firm that prepares

PBA 105's taxes, authored a report about the rate of state income tax withholding

for PBA 105 members during Pay Period 16 and how that rate differed from the

A-1091-23 5 members withholding rate for the supplemental uniform payday made on

January 28, 2022. Of the sampled twelve members, the withholding tax for the

supplemental payday was 2.8% in contrast to the varied withhold tax that ranged

from 3.48% to 5.72% for Pay Period 16. Corcoran opined PBA 105 members

had on average overpaid their state income taxes $20.17, when payment was

made during Pay Period 16.

The State presented the testimony of the Department of Treasury Central

Payroll Supervising Analyst Zachary Burkhalter, who explained that regular

payroll is used to pay regular wages, overtime, and other payments for a specific

time period. On the other hand, supplemental payroll is a "catch-all" pay period

— paid time missed on a regular pay date, or other "lump sum" payments like a

one-time payment for vacation, sick, or compensatory time. According to

Burkhalter, "there is no policy or procedure requiring uniform allowances to be

paid by way of supplemental payroll."

Burkhalter testified that the earliest the uniform allowance could have

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