United Steel Workers v. Gov't of the Virgin Islands

CourtSuperior Court of The Virgin Islands
DecidedAugust 13, 2020
DocketSX-15-CV-250
StatusUnpublished

This text of United Steel Workers v. Gov't of the Virgin Islands (United Steel Workers v. Gov't of the Virgin Islands) is published on Counsel Stack Legal Research, covering Superior Court of The Virgin Islands primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United Steel Workers v. Gov't of the Virgin Islands, (visuper 2020).

Opinion

IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. CROIX

REKKERE

UNITED STEELWORKERS, LOCALS 9488 & 9489, ) ) CASE NO. SX-15-CV-260 Petitioner, ) ) vs. ) ) PETITION FOR WRIT GOVERNMENT OF THE VIRGIN ISLANDS, ) OF REVIEW DIVISION OF PERSONNEL, and PUBLIC ) EMPLOYEES RELATIONS BOARD, ) ) Respondents. ) Cite as 2020 V.I. Super 75 U ) MICHAEL J. SANFORD, Esq. ZULEYMA CHAPMAN, Esq. Sanford Amerling & Associates Assistant Attorney General - Labor 2191 Church Street Office of Collective Bargaining Christiansted, VI 00820-4601 5001 Chandler’s Warf, Suite 10 Attorney for Petitioner Christiansted, V.I. 00820 zuleyma.chapman(@ocb.vi.gov HENRY C. SMOCK, Esq. Attorney for Government of the Virgin Islands SmockLaw, P.C. P.O. Box 1498 LARRY RAYMOND ROY, Esq. St. Thomas, V.1. 00804 P.O. Box 25435 hsmockia@smvilaw.com Christiansted, V.I. 00824

Attorney for Public Employees Relations Board lrroy@iviperb.org Attorney for Public Employees Relations Board

CARTY, RENEE GUMBS, Judge

MEMORANDUM OPINION

(1. THIS MATTER is before the Court upon the Petition for Writ of Review. Petitioners filed their brief on April 12, 2019. Respondents, the Government of the Virgin Islands and the Division

of Personnel (hereinafter “Personnel” or “the Government”), filed their Opposition brief on May 10, United Steelworkers, Locals 9488 & 9489 y. Cite as 2020 V.I. Super 75 U G.V.L, Division of Personnel et al.

Case No. SX-15-CV-260

2019, and Respondents, the Public Employees Relations Board (hereinafter “PERB”), filed its

Opposition brief on May 23, 2019. Petitioners filed their reply on July 24, 2019.

A. BRIEF FACTUAL BACKGROUND q 2. The PERB held hearings on March 10 and 11, 2014, and issued its Decision and Order on June 29, 2015. Petitioners then instituted this writ of review on July 13, 2015. The appeal has been timely filed within the 20 days as required by title 24, section 380 of the Virgin Islands Code. The Court being satisfied in the premises, the PERB’s decision is modified in part and upheld in part. The PERB’s decision is modified as it pertains to Ms. Rochelle Benjamin and Ms. Adonna Duggins and they are permitted to remain in the bargaining unit. However, as it pertains to Ms. Kathleen Simmonds and Ms. Millicent Aubain, this Court holds that the PERB correctly excluded these employees and enforces the PERB’s decision accordingly.

B. LEGAL ANALYSIS

i. Standard of Review for Writ of Review

3. Pursuant to title 24, section 380(a) of the Virgin Islands Code, “any party aggrieved by any final order of the PERB... may appeal to the Superior Court of the Virgin Islands for review of such order.”' In addition, Williams-Jackson v. Pub. Emps. Relations Bd, 52 V.I. 445, 450 (V.1. 2009) echoed section 380(b) by stating that the Court must review “questions of fact to ascertain whether the PERB’s factual determinations were supported by substantial evidence in the records considered

as a whole.”? Substantial evidence is evidence such that a reasonable mind would accept as sufficient

' See also Pub. Emps. Relations Bd. v. United Indus. Workers-Seafarers Int'l Union, 56 V1. 429, 433-34 (VI. 2012); Our Virgin Islands Labor Union v. Pub. Emps. Relations Bd., 71 V.1. 515, 518 (V.I. Super Ct. 2019); Frazer v. Police Benevolent Ass'n, Local 816, 2017 V.I. Lexis 177, at *8-9 (V.L Super. Ct. June 7, 2017).

* 24 V.LC. §380(b). United Steelworkers, Locals 9488 & 9489 v. Cite as 2020 V.L Super 75 U G.V.I, Division of Personnel et al. Case No. SX-15-CV-260

to support the PERB’s decision.*> The primary role of the Court in reviewing a PERB decision is to ultimately “enforce the order, modify the order and enforce it, set the order aside, or return the matter to the PERB with instructions for further proceedings.” ii. Parties’ Arguments

44. Petitioners, in their brief, argue that the issues of access to confidential information as it pertains to Rochelle Benjamin, Financial Management Supervisor; Adonna Duggins, Personnel Records Management Supervisor; Kathleen Simmonds, Supervisor of Recruitment and Classification; and Millicent Aubain, Territorial Administrator, Recruitment and Classification do not implicate any labor relations or collective bargaining matters. They argue that the PERB incorrectly barred them from remaining in the collective bargaining unit because of their alleged classification as confidentia! employees.

45. The Government, in its Opposition, argued the following points: (1.) much like other jurisdictions have outlined, because the employees in question are Personnel employees and thus are confidential personnel, this alone should be sufficient to exclude them from the bargaining unit,” (2.) inclusion in the collective bargaining unit is a fundamental conflict of interest because these Personnel employees are subject matter experts on issues that implicate labor relations and collective bargaining proceedings and their dual role as government employees and union participants disadvantages the

government when it comes to union issues,° and (3.) their job duties render them as confidential

3 Williams-Jackson v. Pub. Emps. Relations Bd., 52 V.1. 445, 450 (V.1. 2009) (citing Lockhart v. Matthew, 250 F. Supp.2d 403, 412-13 (D.V.I. 2002).

424 V.LC. 380(c).

* Government's Brief, pp. 4 & 5 (citing statutory provisions from other jurisdictions that explicitly exclude PERSONNEL employees from bargaining unit. These jurisdictions include Delaware, D.C., Iowa, Montana, Ohio, and Pennsylvania). ® See generally Government's Brief, pp. 6-8. Elaborating that DOP personnel oversee collective bargaining issues such as “terminations, suspensions, demotions, reprimands, promotions, job classifications, employee certifications, employee

3 United Steelworkers, Locals 9488 & 9489 vy. Cite as 2020 V.I. Super 75 U G.V.L, Division of Personnel et al.

employees and based on prior PERB cases, these employees cannot be placed in these bargaining units due to their continued exposure to confidential personnel information.’ In similar fashion, Respondent PERB also filed an opposition brief, reiterating that in accordance with its own precedent, the confidential nature of these employees’ jobs necessitated exclusion from the bargaining unit.

iii. The first question for this Court is whether the employees are confidential employees.

(6. InNLRB vy, Hendricks Cty. Rural Elec. Mbrshp. Corp., 454 U.S. 170 (1981), the U.S. Supreme Court held that the “labor nexus test” is the appropriate test in determining the eligibility of confidential employees to participate in collective bargaining units under the National Labor Relations Act (hereinafter “NLRA”). In particular, the labor nexus test looks at whether the confidential employee “formulates, determines, or effectuates management policies in the field of

labor relations.’”

An employee’s status as a confidential employee is a question of fact that is reviewed using the standard of substantial evidence. NLRB v. Meenan Oil Co., L.P., 139 F.3d 311, 317 (2d. Cir. 1998). In order to be classified as a confidential employee, it is insufficient that the employee is exposed to confidential, sensitive information; a confidential employee classification requires more: that (1.) the confidential information is information that the Union has no advance knowledge of or access to, and (2.) directly implicates grievance proceedings, collective bargaining

issues, contractual negotiations, and other labor relations functions.'° Many courts have narrowly

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
United Steel Workers v. Gov't of the Virgin Islands, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-steel-workers-v-govt-of-the-virgin-islands-visuper-2020.