March 2002

Teamsters set sights on LAPD

The fact that the union representing Los Angeles' rank and file police officers is now an AFL-CIO affiliate apparently is not preventing a raid attempt by the International Brotherhood of Teamsters. In February, the Teamsters launched an effort to oust the Los Angeles Police Protective League (LAPPL) as bargaining agent for the 8,200 LAPD officers below the rank of lieutenant. Blue pledge cards are reportedly being distributed in an effort to force a representation election. The Teamsters' effort would appear to conflict with the AFL-CIO prohibition on raiding of other brother unions. Last December, the LAPPL became a local union of the AFL's International Union of Police Associations.

When asked about the anti-raiding rule, Jim Santangelo, president of Teamsters Joint Council 42 and a Teamsters international vice president, characterized the IUPA affiliavion as having been improperly done. "As far as our attorneys are concerned, this isn't a raid," Santangelo said.

LAPPL officials took a contrary view. Union
president Mitzi Grasso said the LAPPL intends to file a complaint with the AFL-CIO. She asserted that the Teamsters did not have the background to represent police officers, a claim that union officials deny. A Teamster spokesman said the union represented officers in 297 police departments in 19 states.

The Los Angeles officers heading the movement to change representation believe that the Teamsters would create a stronger bargaining unit. "It's not the pay right now, it's the working conditions. We're scrutinized right and left," said Craig Lally, an LAPD sergeant who is one of the officers seeking Teamster affiliation. Lally said he has a "gut feeling" that enough dissatisfied officers exist to force a vote on representation.

The campaign comes at a time when LAPD Chief Bernard C. Parks is seeking to retain his job. The LAPPL has strongly opposed another five-year term for Parks. Mayor James Hahn, who the LAPPL supported in last year's election, also opposes Parks' reappointment. The city's police commission will make the final decision on Parks' future.

NYCPBA fights heroes' promotions while facing cutbacks

"The key is to do it according to the mandates of the court and without subverting the collective bargaining process."

The court reference relates to a judicial ruling two years ago that blocked the promotion of 2,000 officers to the detective-specialist rank as being contrary to the labor agreement. At the time the then-Police Commissioner Howard Safir was trying to reward some, but not all, officers for the historic drop in the city's crime rate.

Promotion of the ESU personnel removed them from PBA representation and places them in the Detectives Endowment Association bargaining unit.

The PBA has traditionally objected to economic rewards that benefited only some of its members.

In an unusual move, the New York City Patrolmen's Benevolent Association (PBA) went to court in February to try to block the promotion of 15 members of the NYPD's elite Emergency Service Unit (ESU). Police Commissioner Ray Kelly promoted 15 of the 465 ESU members to the rank of detective-specialist as a reward for their efforts during the September 11 tragedy. The union takes exception to the plan on the grounds that it circumvents their labor contract with the city. Meanwhile, the city's new mayor is proposing to reduce the size of the department in order to meet budget goals.

"The PBA believes that those 15 Emergency Service cops and thousands of other officers deserve to be rewarded for their work before, during, and after September 11," said PBA president Patrick Lynch.

Currently, the department can deploy 38,100 sworn personnel. To maintain current levels of police service the NYPD plans to hire 800 lower paid civilians to perform clerical tasks now done by officers. These officers will be reassigned to the street.

The events of September 11 have placed enormous financial pressures on a city that expects a $4 billion budget deficit for the next fiscal year.

Meanwhile, recently elected Mayor Michael Bloomberg's budget trims the number of police officer jobs by 1,600. Lowering the number of positions is necessary to attain a requested five percent reduction in the overall budget of the department. The reduction in force, to be gained through not filling vacant positions, would bring NYPD authorized strength down to 39,110 officers from a peak of 40,710.

DOJ settles Newark religious discrimination litigation

The U.S. Department of Justice (DOJ) and the City of Newark, New Jersey, have reached an accord over the wearing of facial hair by the city's Muslim police officers. The agreement, which still must be approved by a federal judge, ends DOJ's claim that the city engaged in unlawful religious discrimination against a group of current and former police officers.

In May 2000, the DOJ filed suit alleging that the city discriminated against the officers by failing or refusing reasonably to accommodate their religious observance, practice and belief as Muslims, including wearing a beard. The suit also alleged that the city threatened the Muslim officers with termination, transferred them to undesirable assignments, and denied them opportunities to work special overtime events.

Under the agreement, the city will offer back pay and compensatory damages totaling $53,600 to ten current and former police officers. In addition, the city will implement non-discriminatory employment policies designed to accommodate the employees' religious practices.

"Religious freedom is one of the bedrock principles of our democracy," said Ralph F. Boyd, Jr., Assistant Attorney General for Civil Rights. "The settlement recognizes than an employee's religious expression is not checked at the workplace door when the employer can reasonably accommodate the employee's religious practice."

As part of the settlement, the city will also expunge from the officers' disciplinary records any references to the disciplinary action taken against them.

Officer terminated for wife's behavior

Dible's wife, Megan, earlier quit her job as a part-time dispatcher after a co-worker saw her photos on a Website and told a supervisor. The department requires all employees to sign a code of conduct promise that their activities will not tarnish the department's image.

Eleanor Eisenberg, executive director of the Arizona chapter of the American Civil Liberties Union, said if Dible is being fired because of the Website, the department's actions amount to government punishment for a form of expression protected by the First Amendment.

Dible is not the first Chandler officer to face discipline over the Website. Earlier this year a reserve officer was terminated because his wife posed for the same site.

Regulation of the off duty conduct of police officers is one of the more problematic personnel issues to arise in recent years. Generally, in order to subject an officer to discipline for off-the-job conduct, an employer must show that the behavior adversely affected the operations of the police department. But what about the conduct of a spouse? May a male officer lawfully be disciplined for his wife's behavior? A recent incident in Arizona is raising that unusual question.

The Chandler Police Department has fired an officer whose wife posed for an adult content internet site. Officer Ron Dible was terminated after an investigation into whether he violated the department's code of ethics, according to published reports.
 

Union membership declines slightly according to BLS

Union membership by police officers, fire fighters, and other protective service workers declined slightly over the last year, according to data released in January by the Bureau of Labor Statistics (BLS). In 2001, about 38 percent of employees in protective service occupations belonged to a union, down from 39.4 percent in 2000, but about the same as a decade ago. This rate is the highest of all job categories measured in the nationwide study.

Local government remained the job sector with the highest share of union members at 43.2 percent, with police officers, fire fighters, and teachers enjoying the highest union membership rates. Only about one in ten private sector workers are union members.

While about 2,400,000 protective service workers were union members, less than half that number of workers - just over 1,000,000 - were covered by a labor contract.

In examining all workers' pay for 2001, union members nationwide had a median weekly wage of $718 while non-union workers earned a median weekly wage of $575, a 25 percent differential. The difference at least partially reflects the influence of collective bargaining on wages.

BLS statistics aggregate police officers, fire fighters, and correctional officers into the protective service category and do not report data for the individual occupations.

"CHIPS" go airborne

Federal air security authorities have approved a plan by California Governor Gray Davis to place armed California Highway Patrol (CHP) officers on intrastate commercial aircraft. Under what Davis calls his "safe skies" program, plainclothes CHP officers flying as part of their regular duties will serve as airline guards until an expanded force of federal sky marshals takes over.

The officers must undergo specialized training in analyzing potentially dangerous situations while in the air and reacting appropriately, including the possible use of firearms. The plan calls for federal experts to train groups of CHP officers who, in turn,
will train other officers until the entire 6,700-member force is qualified in airline protection tactics.

Unlike the east coast where railroads move passengers from Boston to Washington, D.C., extensive air service is provided connecting the San Diego - Los Angeles - San Francisco corridor. These shuttle planes operate solely within California.

Davis' plan was originally seen by some as political grandstanding after September 11 but others welcomed it as a commonsense innovation. The Governor pressed the issue with the Bush administration which finally gave its okay in February.

Litigation

Supreme Court update

The high court recently rejected the appeal in Yanco v. United States, No. 01-674. This leaves in place a lower court determination that a police officer's suicide, which was allegedly stress-induced because of misconduct charges, does not qualify for benefits under the federal Public Safety Officers Benefits Act.

Also rejected for review were McLin v. Board of Police Commissioners of Metropolitan St. Louis Police Department, No. 01-755 and City of Lynn, Massachusetts v. Thompson, No. 01-834. The inaction in McLin leaves in place a 15-day suspension a police officer received for making statements asserting that applicants that the department recruited from rural areas lacked racial sensitivity and were "sissies" until they became a police officer. In Thompson , the Supreme Court declined to consider the city's argument that a lower court should not have reinstated a physically abusive officer. The officer's actions had resulted in two large monetary judgments against the city. A lower state court found no explicit public policy permitting the termination of a police officer who violates federal civil rights law.

Disciplinary grounds

Branton was assigned as an internal affairs sergeant. Her duties included the investigation of both internal and external complaints filed against police employees as well as supervising detectives assigned to her division. Under department procedures, at employee disciplinary hearings the internal affairs investigator presented to the city manager the investigative file in support of the disciplinary charges. The file consisted of summaries of interviews with persons knowledgeable of the case. The accused officer was offered the opportunity to respond. At the end of the hearing the assistant city manager, who served as the hearing officer, took the case under advisement and in due course rendered a decision that was not further appealable. In 1995, Branton was assigned to investigate a complaint filed by a female officer against two male officers. The complaint centered around whether one of the male officers had improperly accepted a monetary fee from the other officer for police baton instruction. The complaining officer and the accused officer apparently had developed animosity towards each other stemming from common ambition to become an international police baton instructor. As a result of the investigation concerning the fee the police chief suspended the accused officer for one day. His suspension was appealed and ultimately upheld before the assistant city manager. However, at the hearing the accusing officer testified that she too had been invited by a lieutenant to become an international baton instructor as well. Branton, who was in attendance at the hearing, considered this testimony to be false based on her investigation. Additionally, she had personal knowledge that the hearing officer had not read her reports prior to the hearing and would be unaware that a false statement had been made. Consequently, when the hearing was concluded, Branton approached the assistant city manager and asked to speak to him alone. She then informed him of the inconsistencies between the witness's statement and other investigative information and informed him of her belief that the witness's testimony was false. She made no attempt to influence the outcome of the hearing or to persuade the hearing officer of the appropriateness of the accused officer's punishment. Ultimately, the one-day suspension was reduced to a letter of counseling. Shortly after he received the decision, the police chief informed Branton that she was being transferred out of the internal affairs division because of the post-hearing statement she had made to the hearing officer. She was assigned to handle walk-in complaints, a job viewed by most as highly undesirable. The chief further placed an administrative disciplinary report in her file which retarded her ability to receive a promotion or earn overtime. Branton subsequently claimed she had never been advised of any department policy against reporting a witness's misconduct to the assistant city manager/hearing officer. She later filed suit against the city and the police chief claiming her First Amendment rights were violated for speaking out concerning the false testimony of the police officer at the hearing. The trial court, after some intermediate litigation, granted summary judgment in favor of the city and the police chief. Branton appeals.

HELD: It is well-established law that a governmental employer cannot condition public employment on a basis that infringes on the employee's constitutionally protected interest in freedom of expression. Under prior law, a court must determine whether an employee's speech touches upon a matter of public concern. If so, the employee's interest in speaking out as a citizen upon the matter of public concern must be balanced against the interest of the state in promoting the efficiency of the public service. Matters of public concern are those that can fairly be considered as relating to any matter of political, social, or other concern to the community. Speech that discloses any evidence of corruption and impropriety or malfeasance on the part of city officials is of public concern. Thus, Branton's comments that touched upon alleged improper acts of a public official were a matter of public concern. Although Branton's speech occurred at work, because her job required her to report false testimony at official hearings, she had not only an invitation but a duty to speak out. The evidence shows that her statement caused no unanticipated delays or disruption or interference with the disciplinary proceedings or the functioning of the police department. Similarly, there was evidence that other instances of communication with the hearing officer after the end of a hearing had occurred in the past. The efficiency and morale of the department had not been adversely affected by these prior incidents. The chief of police testified he took the action because she should have known through her experience that such ex parte discussions with the assistant city manager would lead to unfair hearings and loss of confidence among police officers. Concern for maintaining harmony and eliminating disruption, however, cannot be the sole measure of government interest when an employee's speech furthers other important state interests. Branton's comments served the important interest of preventing perjury or other false testimony and corruption within a law enforcement agency. This interest outweighs any concerns about maintaining internal harmony. Thus, Branton's First Amendment rights were affected in this case. Likewise, the chief does not have qualified immunity from suit because for some 30 years before, the law had been clearly established that public employees cannot be sanctioned for their constitutionally protected interest in freedom of speech. A reasonably objective public official in the chief's situation would have known that an adverse employment action against an employee for her speech concerning false testimony by a fellow officer would violate a clearly established constitutional right. Reversed for officer and remanded for further proceedings. [Branton v. City of Dallas, Texas, 272 F.3d 730 (5th Cir. 2001)]
 

Fringe benefits

Villarreal was employed as a police officer for some eight years. One day, while responding to a call for assistance, he was kicked in the knee during the arrest of a suspect. His knee cartilage and ligaments were seriously damaged and he also suffered a broken leg. He was off from duty for nearly one year and was placed on light duty upon his return. Eventually he was able to return to full duty as a police officer and remained in that status for the next ten years. At that time he suffered a second injury to his knee. This injury resulted during the pursuit of a suspect when Villarreal jumped and his knee gave out. After efforts of rehabilitation the village police pension board concluded that he was fully disabled and placed him on a disability retirement. The former officer then began his own construction company. He subsequently wrote a letter to the city asking that he be provided free health insurance coverage based on an Illinois statute that declares that police officers who suffer a catastrophic injury will be provided such free health care coverage. The village denied the request and former officer files suit. Trial court likewise rejected the claim and former officer appeals.

HELD: Illinois law provides that a fulltime law enforcement officer who suffers a catastrophic injury or is killed in the line of duty shall have provided to him or his surviving family the entire premium of the employer's health insurance plan. The statute does not define the meaning of "catastrophic injury." A term that is undefined in a statute must be given its ordinary and properly understood meaning. A dictionary
definition of the term "catastrophic" is ordinarily understood to mean a momentous tragic, usually sudden, event marked by effects ranging from extreme misfortune to utter overthrow or ruin. In the context of an illness the term is defined as an act that is financially ruinous. A "catastrophic injury" which contemplates a ruinous impact on an individual's finances does not encompass Villarreal's knee injury. It is undisputed that he is not rendered incapable of engaging in any gainful employment. He has lost stability and flexibility in his knee but that does not prevent him from working in a wide range of occupations. The mere fact that he cannot currently perform the work of a police officer does not qualify his injury as catastrophic. Other jurisdictions around the country have taken a similar approach to defining catastrophic injury. Since the former officer did not suffer a "catastrophic injury" he is not entitled to the health insurance benefits. [Villarreal v. Village of Schaumburg, 759 N.E.2d 76 (Ill. App. Ct. 2001)]

Duty to defend

Ingram, a city police officer, was sued in federal court by Williams. Williams was a dancer at a nightclub and in her lawsuit complained that on two separate occasions Ingram violated her constitutional rights. She alleged that he improperly detained her and solicited sexual favors from her. In one incident, the officer allegedly pulled her over and administered a breath test. In a second incident, he allegedly extracted her from a taxi, handcuffed her, and placed her inside the police car. City lawyers appeared in court to defend Ingram but subsequently moved to withdraw from the case and refused to further defend him. State law provided that the city shall defend its officers in civil suits if the action complained of was within the scope and arising out of the performance of official duties and responsibilities. The city's refusal to defend the police officer was based on the claim that his conduct was not in the performance of his official duties. Ingram sought a court order to compel the city to provide legal defense. The trial court similarly concluded that his acts were outside the scope of his employment and the city owed him no obligation of a defense. Officer appeals.

HELD: It is undisputed in this case that Ingram is a sworn member of the Indianapolis Police Department and that the lawsuit complains that he used his powers as a police officer to solicit sex. The question presented is the scope of duties of an officer that give rise to the right to be defended in subsequent suits. The city argues that the allegations against the officer would never be viewed as being in the scope of his official duties. However, prior law holds that to be within the scope of employment, conduct must be in the same general nature as that authorized or incidental to the conduct authorized. Such is the case here as the alleged action involved Ingram engaging in his official police duties even if his conduct was improper under the circumstances. Given the way the statute is written, it forms part of the contract of employment of the police officer. Thus, the city is obligated to defend him in the federal court suit. [Ingram v. City of Indianapolis, 759 N.E.2d 1144 (Ind. Ct. App. 2001)] 

  Disciplinary grounds

Williams was a New Orleans police officer. One evening he locked his pistol and police radio in the rear hatchback of his automobile that was parked at his residence. The next day he discovered that someone had broken into the car and stolen personal items including the weapon and radio. Following an internal investigation Williams was suspended for one day and assessed a fine of $400 for violating department regulations concerning the proper care of department property. Williams filed an appeal with the civil service commission. Following a hearing, the commission upheld the fine but reversed the one-day suspension. The commission ruled that while the department had met its burden of proof, the fine was a sufficient penalty. The commission noted that it had heard numerous appeals concerning violations of this particular rule and that in each case individuals had only been fined. The department appeals the commission's ruling on the basis that it acted arbitrarily and capriciously and exceeded its statutory authority by substituting its judgment for that of the department.

HELD: In Louisiana, an employee who gains permanent status in civil service cannot be subjected to disciplinary action by the employer except for cause expressed in writing. Such disciplinary action is subject to review by the city civil service commission. The commission has a duty to independently decide whether the employer had lawful cause for the action and whether the punishment imposed was commensurate with the violation. Legal cause for disciplinary action exists whenever an employee's conduct impairs the efficiency of the public service in which that employee is engaged. When reviewing whether the punishment is commensurate with the infraction, the commission shall be given deference, except if it acts in an arbitrary or capricious manner. "Arbitrary or capricious" means that there is no rational basis for the action taken by the commission. In this case, the commission found that the police department met its burden of proof by showing sufficient cause for the discipline. Rather, it based its alteration of the punishment solely on the fact that it had heard numerous appeals concerning the same rule and that in the past a fine was all that had been meted out. Even if this is true, the fact that the police department may have imposed different penalties on other officers for similar violations is not sufficient justification for the civil service commission to alter the penalty in a case where the department has shown sufficient cause for disciplinary action. Additionally, there was no evidence presented at the hearing regarding the prior disciplinary action in similar cases. The commission exceeded its authority
court rendered a judgment in favor of the police officers. City appeals and acted in an arbitrary and capricious manner. Reversed with one-day suspension reinstated on police officer. [Williams v. New Orleans Police Department, 800 So.2d 1086 (La. Ct. App. 2001)]

Sick leave

Prior to 1980, the city routinely allowed police officers to "run out" their accrued sick leave in anticipation of retirement. This custom arose because supervisors allowed officers to continue to draw their regular salaries without requiring them to report to work until they no longer held any accumulated sick leave. The officers were allowed to use day for day of accumulated sick leave. This custom occurred notwithstanding an official written policy that allowed city employees to convert sick leave to salary at the rate of one day of salary for every five days of accrued sick leave. In 1980, the civil service commission officially adopted the policy of one day credit for five days of accrued leave. Upon adoption of the civil service rule a group of police officers sued claiming that the existence of the long term practice of allowing police officers to run out their sick leave had resulted in an implied contract and that the five-to-one rule deprived them of a vested property right without due process of law. The city moved for summary judgment on the grounds that the alleged contractual agreement violated preexisting written city policy and civil service rules. The trial court granted summary judgment but an appeal resulted in a reversal. A trial was conducted on the matter and trial

 HELD: The city argues that civil service rules limit the use of sick leave to active employees who are legitimately ill or injured. Thus, any alleged contract would be contrary to law and consequently null and void. Additionally, the city argues that no policymaker of the city ever officially approved the practice of running out sick leave. Prior case law holds that a governmental employer's policy of granting paid leave for overtime if well known and routinely followed constituted a legally enforceable contract with the employees subject to it. A similar view must be taken of the matter in hand. The policy of running out sick leave in this case was well known. The evidence indicated that no one was ever disciplined for running out sick leave and that the city was aware of the actual benefit it would receive by discouraging frivolous sick days and preventing manpower shortages. Although the policy was never formally approved by the city, the individuals with authority to make such a policy knew about the practice and did nothing to hinder it or punish participating officers. Indeed, the practice was presented as an option to possible recruits and rookie officers as an inducement to work for the police department. The city should not be credited for any sick leave amounts usually paid to the officers. Affirmed for police officer upholding the policy of permitting the use of sick leave prior to retirement. [LaFleur v. City of New Orleans, 800 So.2d 1112 (La. Ct. App. 2001)]
 

Settlements

Chicago, Illinois

police officers

A four-year contract previously rejected by Chicago police officers has been imposed upon them by an arbitrator. The retroactive agreement provides a two percent pay boost as of July 1, 1999, and three consecutive four percent increases on January 1 of each of the following years. A final two percent will be awarded on January 1, 2003. When compounded over the life of the agreement the pay hikes will equal 17 percent. As of January 1, 2002, starting base wage becomes $38,462 while veteran officers draw a base over $67,900. The clothing allowance will be increased by $200 in both 2001 and again in 2002. In addition, officers will receive an increase of $300 per year in duty availability allowance, a form of shift differential pay. The contract extends the probationary period for new officers from 12 months to 18 months. Lodge 7, Fraternal Order of Police (FOP), the bargaining representative for patrol officers and detectives, will now be required to reimburse the city for the salaries of seven individuals temporarily assigned to the FOP.

Tigard, Oregon

police officers

After more than a year of negotiations the 54-members of the Tigard Police Department have obtained a new contract. The three-year pact between the Tigard Police Officers Association and the city is retroactive to July 1, 2001. In the first year, sworn officers take a wage pass while non-sworn gain a 3.5 percent pay hike. The city does pay a six percent contribution to the employee retirement system for the sworn. In the remaining two years, all personnel will receive between a 2.5 and 5 percent wage boost depending on changes in the Consumer Price Index. In addition, equipment allowance was jumped from $50 to $100 annually.

Wauwatosa, Wisconsin

police officers

Raises of 3.4 percent in 2002 and 2003 along with a 3.5 percent pay boost in 2004 highlight the new contract between the Wauwatosa Peace Officers Association and the city. In exchange for the pay boosts, the association agreed to concessions on health care coverage and expenditures. The agreement marks the first time in a quarter of a century that a new agreement has been reached before the existing contract expired.

Worcester, Massachusetts

police officers

An arbitrator's decision has given members of Local 378 of the International Brotherhood of Police Officers a new three-year contract. The pact provides a four percent wage hike in each year retroactive to July 2000. On the last day of the contract, June 30, 2003, officers will receive an additional three percent pay raise. With the pay boosts senior patrol officers will now draw $46,130 annually with another four percent coming in July.