The Atlantic City Policemen's Benevolent Association Local 24 v. City of Atlantic City

CourtNew Jersey Superior Court Appellate Division
DecidedApril 7, 2025
DocketA-2478-23
StatusUnpublished

This text of The Atlantic City Policemen's Benevolent Association Local 24 v. City of Atlantic City (The Atlantic City Policemen's Benevolent Association Local 24 v. City of Atlantic City) 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
The Atlantic City Policemen's Benevolent Association Local 24 v. City of Atlantic City, (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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-2478-23

THE ATLANTIC CITY POLICEMEN'S BENEVOLENT ASSOCIATION LOCAL 24 and THE ATLANTIC CITY SUPERIOR OFFICERS' ASSOCIATION,

Plaintiffs-Appellants,

v.

CITY OF ATLANTIC CITY, STATE OF NEW JERSEY, NEW JERSEY DIVISION OF LOCAL GOVERNMENT SERVICES IN THE DEPARTMENT OF COMMUNITY AFFAIRS, and JACQUELYN SUAREZ, Director of the Division of Local Government Services in the Department of Community Affairs in her official capacity,

Defendants-Respondents. _____________________________

Argued on March 12, 2025 – Decided April 7, 2025

Before Judges Mayer and Rose. On appeal from the Superior Court of New Jersey, Law Division, Atlantic County, Docket No. L-2790-23. Kevin D. Jarvis argued the cause for appellants (O'Brien, Belland & Bushinsky, LLC, attorneys; Kevin D. Jarvis and David F. Watkins, Jr., on the briefs).

Ronald L. Israel argued the cause for respondents (Chiesa Shahinian & Giantomasi, PC, attorneys; Ronald L. Israel and Melissa F. Wernick, on the brief).

PER CURIAM

Plaintiffs The Atlantic City Policemen's Benevolent Association Local 24

(PBA) and The Atlantic City Superior Officers' Association (SOA) appeal from

a March 4, 2024 order dismissing with prejudice their complaint against

defendants City of Atlantic City (City), State of New Jersey (State), New Jersey

Division of Local Government Services (DLGS) in the Department of

Community Affairs, and Jacquelyn Suarez, Director of the DLGS (Director).

We affirm.

A-2478-23 2 We recite the facts from the motion record and prior opinions involving

the same parties and similar issues. 1 The 2008 economic recession created an

unprecedented financial crisis in the City. Two years later, the City's continued

financial instability resulted in the State's monitorship of the municipality. From

2010 to 2016, the City's taxable property values fell almost $14 billion. See

Police, slip op. at 6. The City lost $63 million in municipal tax revenue. Ibid.

Fueled by successful tax appeals by casinos, the City's debt reached nearly $500

million. Id. at 7. "Despite the sharp decline in tax revenue, the City failed to

reduce the municipal budget . . . , placing the City in further economic distress."

Id. at 7-8.

The City's financial situation reached a breaking point in 2016, and the

mayor announced plans to shut down non-essential government services.

Associated Press, Atlantic City May Shut Down Nonessential Services for 3

Weeks, N.Y. Times (Mar. 21, 2016). On May 26, 2016, in the midst of the City's

1 See Atl. City Superior Officers' Ass'n v. City of Atlantic City, No. A-3117-20 (App. Div. June 30, 2022); Atl. City Policemen's Benevolent Ass'n Loc. 24 v. Christie, No. ATL-L-0554-17 (Law Div. May 23, 2017) (Police). Although Rule 1:36-3 generally prohibits citation to unpublished cases, courts may cite unpublished decisions for factual and procedural history or "to provide a full understanding of the issues presented." Zahl v. Eastland, 465 N.J. Super. 79, 86 n.1 (App. Div. 2020); see also Pressler & Verniero, Current N.J. Court Rules, cmt. 2 on R. 1:36-3 (2025).

A-2478-23 3 fiscal crisis, plaintiffs and the City entered into memoranda of agreements

(MOAs) for promotion of police officers with no increase in pay until the parties

and the State ratified a salary increase, or salary increases were awarded by an

interest arbitrator.

The Municipal Stablization and Recovery Act

The following day, on May 27, 2016, Governor Chris Christie signed the

Municipal Stablization and Recovery Act (MSRA), N.J.S.A. 52:27BBBB-1 to -

17, into law addressing the City's dismal financial situation. The MSRA

established a procedure for determining "whether a municipality should be

deemed a municipality in need of stabilization and recovery." 2 N.J.S.A.

52:27BBBB-4(a).

The MSRA authorized an appointed Director to take "any and all actions

that, in the exclusive discretion of the [D]irector, may help stabilize the finances,

restructure the debts, or assist in the financial rehabilitation and recovery of the

municipality in need of stabilization and recovery." N.J.S.A. 52:27BBBB -

5(a)(3). Those actions included:

2 A municipality in need of stabilization and recovery is a municipality that, within the last five years (1) "has experienced a decrease of more than [fifty] percent in its total" property values; and (2) "has experienced an increase in outstanding debt exceeding [fifty] percent." N.J.S.A. 52:27BBBB-3. A-2478-23 4 (f) . . . unilaterally amending or terminating any contracts or agreements . . . to which the municipality is a party, provided that the [D]irector determines that the unilateral termination or amendment is reasonable and directly related to stabilizing the finances or assisting with the fiscal rehabilitation and recovery of the municipality in need of stabilization and recovery;

(g) unilaterally modifying, amending, or terminating any collective negotiations agreements, except those related to school districts, to which the municipality is a party, or unilaterally modifying, amending, or terminating the terms and conditions of employment during the term of any applicable collective negotiations agreement, or both, provided that the [D]irector determines that the modifications, amendments, or terminations are reasonable and directly related to stabilizing the finances or assisting with the fiscal rehabilitation and recovery of the municipality in need of stabilization and recovery; [and] ....

(i) with respect to any expired collective negotiations agreement to which the municipality in need of stabilization and recovery is a party, unilaterally modifying wages, hours, or any other terms and conditions of employment[.]

[Ibid.]

On June 6, 2016, the Commissioner of the Department of Community

Affairs (Commissioner) designated the City a municipality in need of

stabilization and recovery. Police, slip op. at 10. On November 9, 2016, the

Local Finance Board vested the Director with the MSRA's powers. The MSRA

A-2478-23 5 authorized the appointment of a Designee for the Director. The Designee was

authorized to exercise all powers entrusted to the Director under the MSRA.

The MOAs

Plaintiffs are employed by the City as police officers. In 2013, plaintiffs

executed collective negotiation agreements (CNAs) with the City through the

end of 2015. The parties were unable to agree to new CNAs before January 1,

2016, but continued to negotiate. During the continued negotiations, the City

recognized the need to promote police officers but lacked the financial ability to

pay salary increases associated with job promotions.

The day before enactment of the MSRA, the City entered into MOAs with

plaintiffs, authorizing police department promotions without concomitant raises.

The PBA's MOA provided:

[T]he City may effectuate . . . promotions . . . from Police Officer to Sergeant with no increase in pay until a salary increase, including rank [differential] and any other increase, is ratified between the City, the State Monitor, and the PBA, or until such salary increases are awarded by an interest arbitrator . . . .

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