Township of Green Brook v. Pba Local 398

CourtNew Jersey Superior Court Appellate Division
DecidedFebruary 21, 2025
DocketA-0853-23
StatusUnpublished

This text of Township of Green Brook v. Pba Local 398 (Township of Green Brook v. Pba Local 398) 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
Township of Green Brook v. Pba Local 398, (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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-0853-23

TOWNSHIP OF GREEN BROOK,

Plaintiff-Respondent,

v.

PBA LOCAL 398,

Defendant-Appellant. ______________________________

Submitted February 5, 2025 – Decided February 21, 2025

Before Judges Mayer and Puglisi.

On appeal from the Superior Court of New Jersey, Chancery Division, Somerset County, Docket No. C-012051-23.

Mets Schiro & McGovern, LLP, attorneys for appellant (Leonard C. Schiro and Christa Lamia, of counsel and on the briefs).

Ruderman & Roth, LLC, attorneys for respondent (Mark S. Ruderman and Littie E. Rau, of counsel and on the brief).

PER CURIAM Defendant PBA Local 398 (PBA) appeals from a November 13, 2023

order vacating in part and affirming in part a June 14, 2023 arbitration award.

The arbitrator required plaintiff Township of Green Brook (Township) to pay

the retirement health care benefits for PBA member and retired Township Police

Officer John Skikus. The arbitrator also determined there was no meeting of the

minds between the Township and the PBA regarding the payment of health

insurance premiums for retirees with less than twenty years of creditable service

as of June 2011. Thus, the arbitrator remanded for further negotiations between

the parties to address this issue. We affirm the November 13, 2023 order for the

cogent reasons expressed by Judge Haekyoung Suh in her twenty-four-page

written statement of reasons.

The Township hired Skikus on February 1, 1993. He retired from the

Township's police department on February 1, 2018, having accrued twenty-five

years of creditable service during his tenure as a police officer. However, as of

June 28, 2011, Skikus lacked the required twenty years of service under N.J.S.A.

52:14-17.28d(b)(3) to receive free health care benefits.1

The Township and the PBA entered into a collective bargaining agreement

(CBA) covering the period between January 1, 2010, to December 31, 2013.

1 N.J.S.A. 52:14-17.28d is also referred to as Chapter 78. A-0853-23 2 Article IX, F of the CBA provided "[e]mployees who retire with twenty-five . . .

years of public service shall have their and their eligible dependents['] health

insurance benefits continued . . . with the premium of period charges paid by the

Township." The CBA also stated "[a]ny increase in the cost of such coverage

during the lifetime of this [a]greement shall be borne by the Township." The

CBAs between the Township and the PBA since at least January 2006 and

through December 31, 2023 contained similar provisions.

Prior to Skikus retiring, the Township's chief municipal financial officer

sent a letter to Skikus stating the Township would continue paying his health

care benefits costs. For two years following his retirement, Skikus received

fully paid retiree health benefits from the Township.

On June 28, 2011, before Skikus retired, the Legislature enacted N.J.S.A.

52:14-17.28d. The statute required all public employees and retirees to pay a

percentage of the cost of their health insurance benefits. N.J.S.A.

52:14-17.28d(b)(1). The health insurance contribution to be paid by public

employees and retirees was phased in over a four-year period. N.J.S.A.

52:14-17.28d(a). Those retirees with twenty or more years of creditable service

as of June 28, 2011 were exempt from contributing to their health care benefits

insurance premiums. N.J.S.A. 52:14-17.28d(b)(3). At the end of the four-year

A-0853-23 3 phase-in, effective June 28, 2015, the parties to any collective negotiations

agreement were required to "conduct negotiations concerning contributions for

health care benefits as if the full premium share was included in the prior

contract." N.J.S.A. 52:14-17.28d(b)(2)(e).

In a February 7, 2020 letter, the Township notified Skikus:

[I]t has come to our attention that under Chapter 78 of P.L. 2011, you are required to contribute towards the cost of your health benefit premium. Under the law, employees that may be eligible for lifetime health benefits by obtaining [twenty-five] years of service, but did not have [twenty] years of service as [of] June 28, 2011 must contribute towards the cost of the premiums.

Until recently, the Township was not aware that based on the rules of Chapter 78, the [S]tate only does direct deductions for health benefit contributions from pension checks for Chapter 48 towns, not Chapter 88, like Green Brook. Therefore, you are required to pay the Township directly and are not eligible for a direct deduction from your pension check from the State.

As of June 28, 2011, Skikus had only eighteen years of credible service.

Upon receipt of the Township's February 2020 letter, Skikus paid approximately

$23,000 to the Township, representing his uncollected health care benefits

contribution from February 2018 to April 2020. In April 2020, Skikus started

paying his health care benefits insurance contribution directly to the Township.

A-0853-23 4 On April 6, 2022, the PBA filed a grievance with the Township contesting

Skikus's required contribution for health care benefits. The Township denied

the grievance. On May 5, 2022, the PBA requested arbitration with the Public

Employment Relations Commission (PERC).

PERC assigned the matter to an arbitrator. The parties agreed the

arbitrator would decide whether the Township violated Article IX, F of the CBA

by requiring Skikus to contribute to the cost of his retiree health care benefits.

If the arbitrator found the Township violated the CBA, the parties further agreed

the arbitrator would determine the appropriate remedy.

After hearing testimony and reviewing the parties' submissions, the

arbitrator rendered a June 14, 2023 award. In his sixteen-page award, the

arbitrator found:

1. The Township violated the Negotiated Agreement when it failed to continue to pay retiree health insurance premiums for [John] Skikus. The Township shall make [John] Skikus whole, retroactively and prospectively, for its failure to do so.

2. The issue of retiree health insurance premiums is remanded to the parties for collective negotiations.

Additionally, the arbitrator held the doctrine of equitable estoppel

precluded the Township's collection of health care benefits contributions from

Skikus. The arbitrator found "[i]t [wa]s clear . . . that Skikus'[s] decision to

A-0853-23 5 retire when he did was based, in part at least, upon the lack of health premiums

he would have to pay" and his "circumstances f[e]ll squarely within the doctrine

of detrimental reliance."

Regarding health care benefits contributions to be paid by PBA members

who retired after 2011 without twenty years of creditable service, the arbitrator

found "the parties did negotiate the issue as required by law but did not come to

an agreement." Based on contradictory arguments advanced by the PBA and the

Township on this issue, the arbitrator remanded for further negotiations between

the parties.

About a month after the arbitrator rendered his award, the Township filed

a verified petition and order to show cause (OTSC) in the Superior Court to

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Township of Green Brook v. Pba Local 398, Counsel Stack Legal Research, https://law.counselstack.com/opinion/township-of-green-brook-v-pba-local-398-njsuperctappdiv-2025.