Wash. State Council of County & City Emps. v. City of Spokane

CourtWashington Supreme Court
DecidedDecember 8, 2022
Docket100,676-4
StatusPublished

This text of Wash. State Council of County & City Emps. v. City of Spokane (Wash. State Council of County & City Emps. v. City of Spokane) is published on Counsel Stack Legal Research, covering Washington Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wash. State Council of County & City Emps. v. City of Spokane, (Wash. 2022).

Opinion

NOTICE: SLIP OPINION (not the court’s final written decision)

The opinion that begins on the next page is a slip opinion. Slip opinions are the written opinions that are originally filed by the court. A slip opinion is not necessarily the court’s final written decision. Slip opinions can be changed by subsequent court orders. For example, a court may issue an order making substantive changes to a slip opinion or publishing for precedential purposes a previously “unpublished” opinion. Additionally, nonsubstantive edits (for style, grammar, citation, format, punctuation, etc.) are made before the opinions that have precedential value are published in the official reports of court decisions: the Washington Reports 2d and the Washington Appellate Reports. An opinion in the official reports replaces the slip opinion as the official opinion of the court. The slip opinion that begins on the next page is for a published opinion, and it has since been revised for publication in the printed official reports. The official text of the court’s opinion is found in the advance sheets and the bound volumes of the official reports. Also, an electronic version (intended to mirror the language found in the official reports) of the revised opinion can be found, free of charge, at this website: https://www.lexisnexis.com/clients/wareports. For more information about precedential (published) opinions, nonprecedential (unpublished) opinions, slip opinions, and the official reports, see https://www.courts.wa.gov/opinions and the information that is linked there. For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. FILE THIS OPINION WAS FILED FOR RECORD AT 8 A.M. ON DECEMBER 8, 2022 IN CLERK’S OFFICE SUPREME COURT, STATE OF WASHINGTON DECEMBER 8, 2022 ERIN L. LENNON SUPREME COURT CLERK

IN THE SUPREME COURT OF THE STATE OF WASHINGTON

WASHINGTON STATE COUNCIL OF ) COUNTY AND CITY EMPLOYEES, ) No. 100676-4 AFSCME COUNCIL 2, AND LOCAL ) 270 thereof, ) ) En Banc Respondents, ) ) v. ) ) Filed: December 8, 2022 CITY OF SPOKANE, a Washington ) municipal corporation, ) ) Appellant. ) )

JOHNSON, J.—This case asks whether a municipal ordinance, requiring

that all collective bargaining between the city and union representatives be

conducted in a manner that is open to the public, is preempted by state law and

unconstitutional under article XI, section 11 of the Washington State Constitution.

The trial court ruled that section 40 of the Spokane City Charter is preempted by

chapter 41.56 RCW, the Public Employees’ Collective Bargaining Act (PECBA), For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. WSCCCE v. City of Spokane, No. 100676-4

and the Public Employment Relations Commission (PERC),1 and granted summary

judgment for the plaintiff. We granted direct review and affirm.

FACTS AND PROCEDURAL HISTORY

The City of Spokane’s (City) city charter was amended in 2019, and section

40 at issue here was added. This section provides:

[A.] As of December 1, 2019, the City of Spokane will conduct all collective bargaining contract negotiations in a manner that is transparent and open to public observation both in person and through video streaming or playback. This section does not require the city to permit public comment opportunities during negotiations. [B.] The City of Spokane shall provide public notice of all collective bargaining negotiations in accordance with the Open Public Meetings Act (RCW 42.30.060-42.30.080.) [C.] The City of Spokane shall publish and maintain all notes, documentation, and collective bargaining proposals on the city’s official website within two business days of their transmission between negotiating parties. [D.] The City of Spokane shall publish all final collective bargaining agreements on the city’s official website for the life of the agreement. [E.] Any elected official or an elected official’s agent who is determined by the City Ethics Commission to have participated in any collective bargaining negotiation in violation of this charter amendment shall be referred to the City or County Prosecutors office for appropriate action. [F.] Open to the public observation does not include meetings related to any activity conducted pursuant to the enforcement of a collective bargaining agreement (CBA) after the CBA is negotiated and executed, including but not limited to grievance proceedings.

1 PERC settles issues between state employers and employees, as established under chapter 41.58 RCW.

2 For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. WSCCCE v. City of Spokane, No. 100676-4

Clerk’s Papers (CP) at 4.

The collective bargaining contract between the Washington State Council of

County and City Employees, AFSCME Council 2 (Union) and the City expired on

December 31, 2020. Prior to its expiration, the Union wrote to the City’s labor

relations manager that it desired to engage in traditional labor negotiations for

renewal of the contract and included proposed ground rules for negotiations. The

rules included a condition that the negotiating meetings be closed to the public. In

response, the City informed the Union it intended to conduct the bargaining

negotiations open to the public, consistent with section 40 of the city charter.

Through counsel, the Union drafted an opinion letter pointing out that the City’s

open bargaining rule is a violation of state law to which the City responded that it

had not implemented open bargaining and were willing to negotiate in good faith.

The parties then agreed to a private, virtual meeting to discuss ground rules

on January 20, 2021, after the expiration of the employment contract. Prior to the

meeting, the City sent a “what if” contract proposal that included the following

public disclosure requirements: “The parties agree to share this What-If proposal,

and subsequent What-If Counterproposals with the public through the City’s

website and social media platforms.” CP at 57. The Union continued to object to

public bargaining and rejected the public disclosure provision of the what if

proposal, which it communicated to the City in several e-mails sent between

3 For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. WSCCCE v. City of Spokane, No. 100676-4

January and March. By March 2021, the City and the Union still could not agree to

a set of negotiation ground rules. The Union continued to demand the use of

ground rules used in prior negotiations, while the City stated it could not agree to

the closed meetings and urged the Union to consider proposal alternatives that

promote transparency and public accountability.

The e-mail exchanges continued and the parties agreed to several meetings,

but they failed to reach an agreement on ground rules. The Union insisted that it

did not agree to the open meeting proposal, and while the City agreed to meet

privately, it insisted that any proposals and agreements be posted to the City’s

website. No agreement was reached. 2

On May 3, 2021, the Union filed this action in Spokane County Superior

Court, seeking declaratory judgment against the City. The Union alleged that

section 40 is contrary to PECBA and is thus preempted. The City unsuccessfully

moved to dismiss the action. The Union filed a motion for summary judgment,

which the trial court granted. The trial judge ruled that PECBA preempted section

40 and thus made section 40 unconstitutional under article XI, section 11 of the

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Wash. State Council of County & City Emps. v. City of Spokane, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wash-state-council-of-county-city-emps-v-city-of-spokane-wash-2022.