Town of Chatham v. Chatham Sergeants and Patrol Officers Union, M.C.O.P., Local 294.

CourtMassachusetts Appeals Court
DecidedSeptember 15, 2023
Docket22-P-0448
StatusUnpublished

This text of Town of Chatham v. Chatham Sergeants and Patrol Officers Union, M.C.O.P., Local 294. (Town of Chatham v. Chatham Sergeants and Patrol Officers Union, M.C.O.P., Local 294.) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Town of Chatham v. Chatham Sergeants and Patrol Officers Union, M.C.O.P., Local 294., (Mass. Ct. App. 2023).

Opinion

NOTICE: Summary decisions issued by the Appeals Court pursuant to M.A.C. Rule 23.0, as appearing in 97 Mass. App. Ct. 1017 (2020) (formerly known as rule 1:28, as amended by 73 Mass. App. Ct. 1001 [2009]), are primarily directed to the parties and, therefore, may not fully address the facts of the case or the panel's decisional rationale. Moreover, such decisions are not circulated to the entire court and, therefore, represent only the views of the panel that decided the case. A summary decision pursuant to rule 23.0 or rule 1:28 issued after February 25, 2008, may be cited for its persuasive value but, because of the limitations noted above, not as binding precedent. See Chace v. Curran, 71 Mass. App. Ct. 258, 260 n.4 (2008).

COMMONWEALTH OF MASSACHUSETTS

APPEALS COURT

22-P-448

TOWN OF CHATHAM

vs.

CHATHAM SERGEANTS AND PATROL OFFICERS UNION, M.C.O.P., LOCAL 294.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

The plaintiff, town of Chatham (town), appeals from the

denial of its motion to vacate an arbitration award and from the

allowance of the cross motion by the defendant, Chatham

Sergeants & Patrol Officers Union, M.C.O.P., Local 294 (union),

to affirm that same award. In 2016, the town, the union, and

Andrew Hutton, a Chatham police officer, entered into a

"settlement and last chance agreement" (settlement agreement)

and a last chance agreement (LCA) that was incorporated therein.

In essence, the two agreements operated to give Hutton a last

chance to avoid termination in exchange for relinquishing

certain rights. Among other things, Hutton agreed that, were he

to be terminated for violating the LCA, he and the union

relinquished the right to grieve under the collective bargaining agreement (CBA) "except on the issue of whether . . . Hutton

engaged in conduct identified herein or in the Last Chance

Agreement." Hutton and the union also agreed to release the

town from various claims, including claims under the CBA. In

addition, the settlement agreement contained an integration

clause providing that the agreement could not be "modified,

amended, or otherwise affected except by a writing signed by all

parties hereto."

After investigating a citizen complaint about Hutton's

conduct on May 14, 2019, the town determined that Hutton had

violated the LCA and notified him of his termination. The union

grieved the termination, and the matter was heard by an

arbitrator who concluded that Hutton's conduct did not rise to

the level of a violation of the LCA. The arbitrator then

proceeded to consider whether Hutton's conduct warranted his

discharge under the "just cause" standard contained in the CBA.

The arbitrator concluded that termination was not warranted

under the just cause standard and imposed a one-week

disciplinary suspension instead.

The central issue in this appeal is whether the arbitrator

exceeded the scope of his authority. Because the arbitrator

went beyond the scope of arbitration to which the parties agreed

in the settlement agreement and the LCA, we vacate the judgment

entered in the Superior Court confirming the award in its

2 entirety pursuant to G. L. c. 150C, § 11 (d), and for the

reasons explained below, we order that a new judgment be entered

confirming the award in part.

Background. Hutton was rehired as a Chatham police officer

in 2007. 1 Thereafter, Hutton received several disciplinary

suspensions, warnings, and written reprimands, as well as

rehabilitative counseling to improve his performance. In

October 2016, the department contemplated terminating Hutton for

alleged violations of various Chatham police department

(department) rules and regulations (rules and regulations). In

lieu of termination, however, on October 11, 2016, the town,

Hutton, and the union, entered into the settlement agreement and

the LCA, under which Hutton agreed to a variety of things,

including a twelve-day disciplinary suspension. In addition,

the settlement agreement contained the following provisions:

"Last Chance: [Hutton] acknowledges that this is his last chance and agrees not to engage in any misconduct or conduct identified outlined [sic] in the 'Last Chance Agreement.' A 'Last Chance Agreement' is attached hereto and incorporated by reference herein. . . . Hutton agrees that if he violates any part of this Agreement, the Town shall have the right to terminate his employment forthwith. Such termination by the Town shall not be grievable or arbitrable under the parties' collective bargaining agreement except on the issue of whether or not [Hutton] engaged in conduct identified herein or in the Last Chance Agreement."

1 Hutton had previously been a member of the department from 2001 to 2003.

3 The LCA, which was incorporated by reference into the settlement

agreement, repeated Hutton's and the union's acknowledgement

that "this [wa]s [Hutton's] last chance" and specified that the

town was entitled to terminate Hutton should he violate any of

six specific provisions of the department's rules and

regulations. Those six provisions are set out in the margin. 2

"1. Rule 5.01 -- Neglect of Duty: 'Officers shall not fail to perform, as directed, all lawful duties required by constituted authority, notwithstanding the officer's normal assignment of duties and responsibilities.'

"2. Rule 5.02 (c) -- Incompetence: 'No Officer shall fail to maintain sufficient competency to perform his duties and to assume the responsibilities of his position. Incompetence may be demonstrated by, but not limited to, the following[:] . . . the failure to conform to work standards established for the officer's rank[,] grade, or position.'

"3. Rule 6.9 -- Truthfulness: 'Officers shall speak the truth at all times.'

"4. Rule 7.01 -- Insubordination: 'Officers shall not be insubordinate. Insubordination shall include: any failure or deliberate refusal to obey a lawful order (written or oral) given by a Superior Officer.'

"5. Rule 9.17 -- Reports: 'Officers shall promptly and accurately complete all reports and forms required by the Department. Before leaving the station house at the end of his tour, [an] officer shall complete all reports and forms which pertain to events occurring during the concluded tour.'

"6. Rule 12.2 -- Falsifying Records: 'Officers shall not knowingly or willingly enter or cause to be entered upon a police report or police record any inaccurate, false or improper information.'"

4 The LCA further provided that, should Hutton violate any of

those six provisions:

"Hutton and the [u]nion agree that the [t]own shall have the right to terminate his employment forthwith. Such termination by the [t]own shall not be grievable or arbitrable under the parties' collective bargaining agreement expect on the issue of whether or not [Hutton] engaged in conduct identified herein."

The LCA was to remain in effect for five years after its

execution, after which it would expire of its own terms.

In addition to the terms and provisions we have set out

above, the settlement agreement contained a release from Hutton

running to the town and also an integration clause. As to the

former, Hutton released the town

"from any and all claims, known or unknown, arising out of or related to the issuance of the suspension and the Last Chance Agreement.

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Cite This Page — Counsel Stack

Bluebook (online)
Town of Chatham v. Chatham Sergeants and Patrol Officers Union, M.C.O.P., Local 294., Counsel Stack Legal Research, https://law.counselstack.com/opinion/town-of-chatham-v-chatham-sergeants-and-patrol-officers-union-mcop-massappct-2023.