Union Township v. Union Township Police Ass'n

81 Pa. D. & C.4th 186, 2007 Pa. Dist. & Cnty. Dec. LEXIS 84
CourtPennsylvania Court of Common Pleas, Lawrence County
DecidedJanuary 30, 2007
Docketno. 70002 of 2006, M.D.
StatusPublished

This text of 81 Pa. D. & C.4th 186 (Union Township v. Union Township Police Ass'n) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Lawrence County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Union Township v. Union Township Police Ass'n, 81 Pa. D. & C.4th 186, 2007 Pa. Dist. & Cnty. Dec. LEXIS 84 (Pa. Super. Ct. 2007).

Opinion

HODGE, J,

This case was before the court on October 31, 2006, for a non-jury trial, on a complaint for declaratory judgment filed by the plaintiff, Union Township, against the Union Township Police Association, pursuant to the Declaratory Judgment Act, 42 Pa.C.S. §7531 etseq.

The Township is requesting in its prayer for relief of its complaint an adjudication that the November 14,2005 collective bargaining agreement extension (C.B.A. extension) and the December 20,2005 addendum to the C.B.A. extension are null, void, and unenforceable by the Police against the Township. In addition, the prayer for relief requests an adjudication that the 2004-2006 C.B.A. is the only valid and enforceable C.B.A.

The Township is also requesting in its prayer for relief the assessment of counsel fees and other relief against the police.

The Police have filed an answer to the complaint, admitting paragraphs 1 through 10 of the plaintiff’s [188]*188complaint, and averring that the C.B.A. extension of November 14, 2005 and the addendum to the C.B.A. extension of December 20, 2005 are valid agreements of the Township. In addition, the Police answer alleges that neither the C.B.A. nor Act 111 require a vote of the municipality in order to reopen negotiations between the Police and the Township.

At the non-jury trial, the court received the testimony of witnesses for the Township, Clair Damon, Kevin Guinaugh, and Sally Byler. In addition, the Township’s exhibits numbers 1 through 33 were marked, admitted, and received by the court.

Testifying on behalf of the Police were Steven Galizia, Patrick Angiolelli, and David Edward Kingston. In addition, defendant’s exhibits A through G were marked and received by the court into evidence.

By way of factual background, it is undisputed that on May 18,2004, the Township and the Police entered into a collective bargaining agreement at a special meeting of the Union Township Board of Supervisors, pursuant to Act 111 of June 24,1968, P.L. 237, number 11,43 P.S. §217.1 et seq. See plaintiff’s exhibit no. 5, the minutes of the special meeting of May 18, 2004.

Admitted into evidence as plaintiff’s exhibit no. 1 was the collective bargaining agreement for the time period of January 1,2004 through December 31,2006. Pursuant to article 2, section 2 of the 2004-2006 C.B.A., prior to January 1,2006, the C.B.A. may be reopened and negotiations/arbitrations may be engaged in the manner directed by Act 111.

[189]*189In calendar year 2005, the Union Township Supervisors were Steven Galizia, Patrick Angiolelli, and Kevin Guinaugh. Supervisor Galizia’s term of office as a township supervisor expired on January 3,2006. On January 3,2006, Clair Damon assumed the office of Union Township Supervisor, following his election to that position on November 8, 2005.

The Township asserts that the Police did not begin negotiations for an extension of the collective bargaining agreement at least six months prior to the start of the fiscal year, in that the Township had no record of any dealings or notice of any dealings between the police and the Township until October of 2005, at which time the Township received a notice of intent to bargain. See plaintiff’s exhibit no. 33, being a letter from Mark Julian of the Police Department dated October 14, 2005. This notice, however, was one year and two and one-half months prior to the expiration date of the original C.B. A., being December 31, 2006.

For calendar year 2005, Supervisor Galizia acted not only as chairman of the Board of Supervisors, but had been appointed at the 2005 reorganizational meeting of the Board of Supervisors as the liaison person by and between the Township and the Police Department. The Township argues in its brief that there was no action of the municipality authorizing Supervisor Galizia to reopen negotiations with the Police. However, the Township points to no statute or case law to support its proposition that action of the municipality is required in order to reopen a collective bargaining agreement containing a re-opener clause.

[190]*190The legal advertisement for the November 14, 2005 special meeting was published in the New Castle News on November 11, 2005. The legal notice advertised a special meeting for the purpose of “personnel matters,” but did not refer to the adoption of a collective bargaining agreement.

The Township takes the position that the notice was insufficient for the Township to vote on the collective bargaining agreement pursuant to section 65504 of the Township Code. As a result, the Township is alleging that the original extension agreement is void and unenforceable.

The minutes of the November 14, 2005 special meeting, plaintiff’s exhibit no.7, indicate that the C.B.A. extension agreement was approved by a vote of two to one, with Supervisor Kevin Guinaugh voting no.

Plaintiff’s exhibit no. 14, being the December 20,2005 regular meeting agenda, approved the minutes of the November 14, 2005 special meeting.

The Township also seeks to void the addendum to the C.B.A. extension agreement dated December 20, 2005, arguing that the addendum was not on the agenda on the December 20, 2005 regular meeting, plaintiff’s exhibit no. 14, and that the minutes of the December 20, 2005, meeting make no mention of a vote on the addendum to the C.B.A. extension agreement. See plaintiff’s exhibit no. 13. On December 27,2005, the Township supervisors held a special meeting, and the minutes reflect that the Board of Supervisors approved the minutes of December 20, 2005, in which there is no mention of a vote on the C.B.A. extension addendum. See plaintiff’s exhibit no. [191]*19115. The Township argues that since there were neither minutes nor a resolution produced authorizing the addendum to the C.B.A. extension agreement, the addendum is void and unenforceable against the Township pursuant to the provisions of the Second Class Township Code.

In addition, the Township argues that the provisions of the Second Class Township Code require that the addendum, being an official action of the Board of Supervisors and being required to be done at a public meeting, must be signed by more than one supervisor, as there is no resolution authorizing one supervisor to sign the addendum agreement on behalf of the Township.

In addition, the Township argued by virtue of its testimony and in its brief that the original C.B.A. extension agreement is null and void as a “lame duck or midnight contract” pursuant to the line of appellate court cases that have held that in the performance of governmental functions, discretionary public commitments cannot be made by officials in office where those commitments will unduly bind their successors in office and where such commitments are made “ultra vires.”

The Police, pursuant to their testimony and the arguments contained in the brief, assert that the parties engaged in lawful, voluntary mid-term bargaining, which is permitted in the C.B.A. as a re-opener, and that mandatory bargaining would not have to begin until June 30, 2006, which would be six months prior to the start of the fiscal year of the Township for the last year of the C.B.A. The Police assert that there is no statutory nor contractual bar to public bargaining of the collective bargaining extension prior to that time.

[192]

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81 Pa. D. & C.4th 186, 2007 Pa. Dist. & Cnty. Dec. LEXIS 84, Counsel Stack Legal Research, https://law.counselstack.com/opinion/union-township-v-union-township-police-assn-pactcompllawren-2007.