January 2003

Police and fire fighters still second in line for smallpox vaccine under new plan

The finalized national plan for smallpox inoculation was announced by the White House December 13 and police officers, fire fighters, and other first responders are second in line for the vaccine.  Police Labor Monthly reported preliminary elements of the plan in the October 2002 issue.  In making the announcement in his weekly radio address, President George Bush said that shots would be mandatory for about 500,000 members of the armed forces and would be recommended for another 500,000 hospital workers and special smallpox response teams.  In the second phase of the plan, shots would be offered to other health workers and first responders.  An estimated 10 million people fall into this category.  These shots would not be mandated but only recommended.  

The timeline for implementation of the plan has not been formalized but is expected to start in January 2003.  Phase two, affecting police officers and fire fighters, will likely begin in the summer.  Shots for the general public will not be available until early 2004.

The Centers for Disease Control also announced that it has completed preliminary review of the plans developed by state health departments for pre-event vaccination of healthcare personnel.  Included in the plans are programs to establish smallpox response teams that will react immediately to any reported incidents.  Some fire fighters, emergency medical personnel, and police officers may be included within these teams.  These individuals will likely be among the first civilians to receive inoculations.

Vaccination of police officers and fire fighters will be voluntary.  Under the federal plan each individual will make a personal decision on whether or not to receive the vaccine.  Because a live virus is used in the vaccine, smallpox vaccination produces side effects ranging from a minor rash to death in rare instances.  

Questions have already been raised concerning who will pay for the collateral costs of the vaccinations.  The federal government will apparently fund the direct costs of the vaccines but Health and Human Services Secretary Tommy Thompson said workers’ compensation insurance would cover any lost work time and public employees’ medical insurance would be expected to pay for the treatment of any side effects.

“We can’t imagine that the government would have the expectation that the cost of a national homeland security program would be borne by employers and their employees,” said Karen Ignagni, president of the American Association of Health Plans.

In his speech, the President emphasized that the government had no information that a smallpox attack was imminent but noted that regimes hostile to the United States were believed to be in possession of the deadly virus. 


Labor Lexicon

Zipper Clause

(From the comparison of such a clause to the closing action of a zipper)

"A clause in a labor contract indicating that the agreement is an exclusive and complete expression of consent. A zipper clause may constitute a waiver of the right to bargain over issues negotiated in or outside the terms of a contract until its expiration."

Merriam-Webster's Dictionary of Law


FOP to serve on National Citizen Corps Council

National President Steve Young has announced that the Fraternal Order of Police (FOP) had been asked to serve as a charter member of the newly formed National Citizen Corps Council. National Secretary Jerry Atnip attended the Council’s first meeting, held at the White House on December 4.  The FOP joins 42 other public and private organizations on the advisory board.  Other law enforcement representatives include the International Association of Chiefs of Police and the National Sheriffs’ Association, but the FOP is the only police labor organization. 

“The Fraternal Order of Police is proud to be a member of this new National Citizen Corps Council to promote citizen preparedness and citizen engagement in homeland security efforts,” said Young.  “Through our work to support Citizen Corps, we can make America’s communities better prepared to respond to disasters of all kinds.”

The National Citizen Corps Council brings together national leaders from first responder groups, emergency management agencies, volunteer service organizations, state and local governments, and the private sector to engage citizens in homeland security and promote community and family safety practices across the country.  The leadership of these organizations and their colleagues at the state and local levels will collaborate to create local Citizen Corps Councils and to advance the mission of Citizen Corps.  The Citizen Corps program is administered by the Federal Emergency Management Agency in cooperation with the Department of Justice and the Department of Health and Human Services.

That's not part of my job — or is it?

One of the curious aspects of policing is that the tasks performed by officers are largely the artifact of tradition and custom.  While many state laws command that officers shall “preserve the peace,” “arrest offenders,” “execute legal process,” and the like, such mandates cover only a few of the broad range of tasks routinely performed by officers.  Likewise, many collective bargaining agreements grant to the members of the police union the right to do all traditional police-related work; these provisions are designed more to limit civilianization and concurrent loss of sworn police officer jobs than they are to define the day-to-day responsibilities of the patrol officer.  Even department manuals tend to focus the appropriate procedure for handling certain types of calls rather than attempting to define the entire scope of the job.

This role ambiguity came to the front in two recent incidents.  A Chicago police officer faces possible disciplinary action after he refused a sergeant’s order to haul a corpse that he suspected was infected with HIV.  Meanwhile, the Massachusetts Supreme Judicial Court has ruled that police officers are under no obligation to perform truancy intervention duties for the public school system unless their employing city bargains the effect of the expanded duties.

In the Chicago case, officers responded to a high-rise residence to investigate a report of maggots in an apartment.  Inside was the corpse of a 41-year-old male.  Someone told the officers that the deceased suffered from HIV.  A 15-year veteran officer subsequently refused to comply with a sergeant’s order to transport the body.  Fire fighters who also responded to the scene called the body a biohazard.
An autopsy subsequently revealed that the deceased died of complications from diabetes.  HIV was not mentioned in the medical report.

Chicago officers have been responsible for transporting corpses since the 1880s.  Over two years ago the city agreed to establish an alternative to using the police for the task but the plan has yet to be implemented.  A spokesman for the Fraternal Order of Police called the handling of dead bodies a safety issue and accused the city of “dragging its feet” in establishing a new protocol.  Disciplinary action against the officer is under review.

Communities in Massachusetts will not have to bargain with police unions over whether officers may be ordered to investigate school truants, thanks to a ruling by the state’s highest court.  But, they may have to negotiate over the effects of such an order.  The dispute dates to 1996 when Worcester school officials asked the city manager to appoint “supervisors of attendance” to locate students who were skipping school.  Because of budget cuts, the school system did not employ its own truant officers.  The city manager established a mandatory procedure for officers to follow when they encountered a student outside of school during school hours.  These new procedures eliminated the discretion officers exercised previously in handling truants.  Local 378 of the International Brotherhood of Police Officers objected on the grounds that assignment of police officers as truant officers was a mandatory bargaining subject.  Though acknowledging that police officers would occasionally pick up truants, union officials claimed the duty was not the responsibility of patrol officers and took away from their law enforcement efforts.

The state labor board ruled that the decision to investigate truancy was an appropriate managerial decision concerning where to deploy public services.  The board further ruled that the general topic was not subject to mandatory bargaining but the city did have to bargain over the impact of the assignment on officers’ workloads.  Hence, the city had committed an unfair labor practice.

When the litigation reached the state’s highest tribunal, the Massachusetts Supreme Judicial Court confirmed that establishment of the compulsory procedures for handling youthful truants was a managerial prerogative outside the scope of mandatory bargaining.  “Setting the priorities for the deployment of law enforcement resources is purely a matter of policy.  A city should not have to bargain over which types of infractions merit more attention from law enforcement than others,” Justice Martha Sosman wrote for the court.  “The allocation of resources among competing law enforcement priorities must be reserved to the sole discretion of the public employer so as to preserve the intended role of the governmental agency and its accountability in the political process.”

However, the court confirmed that Massachusetts’s law does require the impact that a managerial decision might have on wages, hours, and other conditions of employment be subject to collective bargaining.  Because the city waived the latter issue on appeal, the high court refused to consider whether the truancy enforcement decision was subject to impact bargaining.  Presumably, Worcester police officers will not perform truancy intervention duties until such time as an accord is reached with the union on the policy’s impact on workload.

No overtime for sleeping on duty

A New York police union president has lost his bid to obtain overtime pay he said he would have earned during the year he was facing disciplinary charges.  Robert Butler, president of the Rensselaer Police Benevolent Association, was suspended without pay for 30 days last September after an arbitrator found him guilty of sleeping on the job, insubordination, and misuse of a police radio.  Efforts to terminate his employment failed when an arbitrator ultimately put him back to work after finding that his actions did not warrant dismissal from the force.  However, Butler had spent some ten months off the job, with pay, while awaiting the arbitrator’s decision.

At the arbitration hearing, the 24-year veteran officer claimed that he was not sleeping but simply resting.  He argued that police should be allowed to rest, especially while working overtime, to remain alert on the job.  He requested that the arbitrator award him lost compensation he would have earned while suspended.

During the period in question, Butler earned a base salary of over $40,000 and had made a like amount in overtime.  As the longest tenured officer on the force, he held right of first refusal for extra work.

In his ruling the arbitrator denied the claim, noting that the officer was found sleeping on the job while he was earning overtime in the first place.  “In essence, it represents an instance where the grievant (Butler) was being paid for time in which he was not working, in that he was asleep while on duty.  Yet, the very requested remedy is that he be paid for overtime not worked,” arbitrator Thomas Hines wrote.

Butler has also asserted that the disciplinary action was in retaliation for his union activity in speaking out against the department’s command staff.

Litigation


Supreme Court update

In recent weeks the high court justices decided not to review Perez v. Miami-Dade County, Florida, No. 02-269.  This leaves in place a federal appeals court dismissal of an undercover police officer’s suit against a fellow officer.  Perez, the covert officer, claimed that a uniformed officer mistook him for a robbery suspect and intentionally struck him with his patrol vehicle in violation of his constitutional rights.

Recently filed matters of interest include Evans v. DeRidder, Louisiana, Municipal Fire & Police Civil Service Board, No. 02-650, which challenges the admissibility of polygraph evidence at the civil service hearing of a police officer who was accused of disclosing confidential information that may have led to the murder of an informant.  The case seeks Supreme Court review of the acceptability of polygraph evidence in light of changing standards for evaluation and admissibility of scientific testimony in court.

Also seeking review is Macklin v. City of New Orleans, Louisiana, No. 02-741, wherein a police officer, who was working an extra detail while on suspended status, allegedly beat a citizen with his baton.  Although acquitted by a jury on the criminal charge, the police department terminated the officer.  The ex-officer’s efforts at suing the city for discrimination and false arrest have been unsuccessful to date.  He seeks the Supreme Court’s aid in keeping his lawsuit alive, claiming that trial court procedural rules violated his right to a jury trial.

Dismissal grounds

Mercer was a probationary police officer whose husband was a reserve officer.  Mercer was seen socializing at a local tavern with a captain on the police department who had been one of her instructors at the police academy.  Subsequently, the captain’s tires were slashed and Mercer’s residence was damaged.  The husband was suspected of these activities.  The chief of police requested an internal affairs investigation and at some point, Mercer admitted that she was romantically involved with the captain.  Though instructed not to discuss the investigation with anyone except her attorney, Mercer accompanied the captain when he complained to the public safety commissioner about the chief’s handling of the investigation.  Eventually the matter was referred to a management review team consisting of three assistant chiefs.  

Following a meeting, the three-member team recommended that Mercer’s husband be removed from his position as a reserve officer and that Mercer herself be terminated from her position.  Chief subsequently conducted an informal hearing and terminated Mercer’s employment as a police officer, four days short of the completion of her one-year probationary period.  Her husband was also relieved of duty as a reserve officer.  The captain was reassigned but not docked rank or pay.  Following her termination, the police chief was quoted in the local newspaper as saying that Mercer’s employment had been terminated because she “didn’t meet up.”  

Mercer subsequently filed suit against the city alleging that she had been denied equal protection of the law and was the victim of sex discrimination.  She further alleged slander.  Trial court granted summary judgment for the city on all claims except the slander allegation.  The jury subsequently awarded Mercer a monetary judgment on that claim.  City and Mercer both appeal.

HELD:  Mercer contends she was denied equal protection of the law in violation of the Constitution because she was treated differently than a similarly situated male, the captain, who received no discipline for engaging in the same behavior that resulted in her termination.  Prior case law holds, however, that police officers beyond their probationary period are not similarly situated as probationary officers.  Mercer argues that the rule should not apply because she was terminated only four days short of the end of her probationary period.  This argument fails, however, because it is reasonable for the government to distinguish between permanent and probationary employees on issues such as tenure and discipline, even if it results in arguably unfair treatment in a particular case.  

Mercer further argues that the chief was guilty of sex discrimination because he disapproved of her involvement in extramarital sex, but did not disapprove of the man’s involvement.  It may well be that an employer who fires the woman when two employees engage in an office romance would be guilty of gender discrimination; however, there is no evidence that such was the policy of the police department or that the chief intentionally discriminated against female officers.  The differential treatment was permissible.  

Mercer alleges that the chief’s comments to the press after her termination infringed upon a protected liberty interest.  An employee’s liberty interest is implicated when the employer accuses the employee of dishonesty, immorality, crim-inality, racism, and the like because it becomes difficult for the employee to escape the stigma of those charges.  However, no liberty interest of constitutional significance is implicated when the employer has alleged merely improper or inadequate performance or incompetence.  Here, the chief told a reporter that Mercer did not meet police department standards.  These comments do not infringe upon a constitutionally recognized liberty interest.  The chief simply restricted his remarks to Mercer’s ability to perform her job.  The city argues that the slander claim against the city should also be overturned because the court applied the wrong rule.  In order for Mercer, who is considered a public figure, to recover damages for slander, the First Amendment requires that it be shown that the statements were made with actual malice as well as being false.  The falsity element consisted of the chief’s statement that Mercer did not “meet up.”  The falsity of this statement need not be decided because the chief did not speak with actual malice as the First Amendment requires.  Actual malice means ill will, hatred, or wrongful motive.  It also includes false statements made with reckless disregard for the truth.  A review of the facts, however, reveal that the chief did not claim Mercer was incompetent, but merely that she did not meet up to department standards.  In the broad sense, he was not speaking with reckless disregard to the truth because a lengthy internal investigation and informal hearings had persuaded the chief that Mercer had violated various departmental rules and regulations.  A somewhat similar term was actually used in the discharge letter he wrote to Mercer.  Consequently, Mercer has failed to prove that the chief spoke with actual malice.  Absent such a showing, she was not defamed.  Judgment for city.  [Mercer v. City of Cedar Rapids, Iowa, 308 F.3d 840 (8th Cir. 2002)]

Dismissal grounds

A Colorado resort community employed its own security personnel.  Bass worked as chief of that force.  Because the community was not a political entity, the sheriff deputized the community’s officers as reserve deputies in order to have authority to make arrests and investigate crimes.  Though Bass and the other officers were located at the resort community as reserve deputies, they were under the supervision of the sheriff’s department.  

In 1997, Bass talked with his friend, Vorhies, about Vorhies’ interest in running for the office of sheriff.  Bass began privately supporting Vorhies’ effort against the incumbent sheriff although he never campaigned or otherwise publicly supported the effort.  When the sheriff became aware of Bass’s private support for Vorhies, Bass was informed through his supervisor that he should not politic against the sheriff and that he owed loyalty to the sheriff.  At the meeting, Bass denied supporting Vorhies, but did reveal that he preferred Vorhies’ political philosophy to that of the incumbent sheriff.  At that time the sheriff considered pulling Bass’s reserve deputy commission but decided the action would violate Bass’s First Amendment rights.  

However, about six months later, following an unrelated incident, Bass’s reserve deputy commission was permanently revoked.  He maintained his position with the resort community for about ten months more when he was terminated from that position.  Bass filed suit against the sheriff alleging that the loss of his commission based on his preference for Vorhies violated his First Amendment rights of free speech and free association.  County moved for summary judgment on the grounds that Bass had only privately supported an unannounced candidate and that any right he may have had was not clearly established at the time.  Trial court rejected the motion for summary judgment and county appeals.

HELD:  The county argues that Bass’s speech and association rights were not violated by the removal of his commission.  The county contends that Bass lost his job at the resort ten months after the commission and thus the removal had no immediate effect on his employment that could infringe upon the constitutional right.  

However, a government need not cause an individual to lose his job in order to infringe on constitutionally protected activity.  The government infringes upon protected activity whenever it punishes or threatens to punish protected speech.  Depriving or threatening to deprive Bass of his commission as a peace officer was punishment that could inhibit speech and could infringe on his First Amendment rights.  As to Bass’s free speech claim, the First Amendment protects free speech on matters of public concern.  Generally, speech involves a matter of public concern when it is in the interest of the community, whether for social, political, or other reasons rather than a matter of mere personal interest to the speaker.  Bass’s speech related to his assessment of the viability of potential sheriff candidates.  Such political speech is at the core of protected speech.  It is irrelevant that he only spoke to employees in the sheriff’s department and not the public at large.  Bass’s right to speak on such matters was also clearly established.  A reasonable official would understand that removing his commission based on his express preference of one individual’s philosophy over another would violate Bass’s free speech rights.  

As to his association claim, an employee establishes a violation of associational rights if he demonstrates that political affiliation was a motivating factor behind his dismissal from a position that did not require political allegiance.  The county concedes that Bass’s loss of the commission was politically based and that his position did not require political allegiance, but argues that that law was not clearly established at the time the commission was revoked.  However, prior case law has stated that official pressure to work for political candidates not of the worker’s own choice clearly violates the First Amendment.  Further cases hold that support or membership in a political party are not valid grounds for termination of a government employee whose position does not demand political loyalty.  Because a reasonable public official would understand that Bass’ commission could not be removed simply because of his political alignment or beliefs, the sheriff is not entitled to qualified immunity.  Rejection of motion for summary judgment affirmed.  Matter remanded for further proceedings.  [Bass v. Richards, 308 F.3d 1081 (10th Cir. 2002)]

Defamation

Several individuals, along with the American Civil Liberties Union (ACLU), filed suit challenging the constitutionality of a Nevada statute that declared it a misdemeanor to knowingly file false allegations against a peace officer.  The plaintiffs contend that the statute violates the First Amendment.  Parties move for summary judgment.

HELD:  Nevada statute provides that “a person who knowingly files a false or fraudulent written complaint or allegation of misconduct against a peace officer for conduct in the course of and scope of his employment is guilty of a misdemeanor.”  The ACLU argues that the statute is unconstitutional on its face as a violation of the free speech clause of the First Amendment.  They rely on a court ruling that a somewhat similar California penal law was declared unconstitutional.  

U.S. Supreme Court has held that content-based regulations are presumptively invalid.  A statute regulating speech is content neutral only if the state can justify it without reference either to the content of the speech it restricts or the direct effect of that speech on listeners.  If the state’s justifications for the statute stem from the direct communicative impact of the speech, then the statute regulates speech on the basis of its content.  Clearly, the statute in question here  is content-based.  It criminalizes defamation which is critical of police officers only and not other public officials.  Consequently, it is presumptively invalid.  The statute can stand, however, if it falls within one of the three exceptions set forth by the Supreme Court.  The court has ruled that content-based speech is permissible where: (1) the basis of the content discrimination consists entirely of the very reason the entire class of speech is prescribable; (2) where the content defined subclass of speech happens to be associated with particular secondary effects of the speech so that the regulation is justified without reference to the content; or (3) where the nature of the content discrimination is such that there is no realistic possibility that official suppression of ideas is afoot.  As to the first exception, the state argues that treating peace officers different than other public officials is appropriate because peace officers are sometimes subject to violence in their job.  Likewise, allegations of official misconduct lower public confidence in peace officers, thereby increasing the potential for violence.  Finally, allegations of official misconduct damage the working relationship between the police and the community.  

While each of these reasons may justify treating peace officers differently regarding the statutes of assault, battery, and murder, none of the reasons justify treating the officers differently with regard to false allegations of misconduct.  The state has made no showing that there is a serious problem of false allegations of police misconduct leading to violence against police officers.  Therefore, the statute cannot stand on this ground.  As to the second exception, the state offers no grounds to justify that the statute is associated with any particular secondary effects of the speech.  Nor can the court think of legitimate secondary effects to justify the content-based distinction here.  Finally, as to the third exception, the state argues that the speaker knows the statement is false and, therefore, the government is not suppressing ideas.  

However, it is nonetheless realistic to conclude that the statute might have the effect of deterring legitimate complaints against peace officers.  Consequently, the statute cannot be justified on this basis.  Given that content-based regulations are presumed unconstitutional subject to limited exceptions and none of the exceptions fit the Nevada statute in question, the court must rule that the statute violates the First Amendment and is unenforceable.  [Eakins v. State of Nevada, 219 F.Supp.2d 1113 (D. Nev. 2002)]

Disciplinary procedures

In 1990, San Diego County voters amended the county charter to require the establishment of a Civilian Law Enforcement Review Board (CLERB).  The purpose of the board was to advise county government and the sheriff on matters relating to the handling of citizens’ complaints brought against peace officers and certain other county employees.  The CLERB was to make findings of misconduct and recommend discipline against individual deputies as well as recommend changes in sheriff’s department policy as appropriate.  The CLERB did not have authority to actually impose discipline.  

Subsequently, three separate incidents occurred involving four deputies.  These incidents ranged from alleged misconduct in handling a homicide investigation to excessive use of force and unethical behavior.  When the CLERB responded to complaints about these matters, it made general recommendations for policy changes.  The CLERB also sustained findings of serious misconduct against the deputies involved but did not make a disciplinary recommendation.  

However, the sheriff’s department internal investigation of the same incidents found no misconduct on the part of any of the deputies.  Counsel for the deputies sought a hearing before the Civil Service Commission claiming that the CLERB findings affected the liberty interests of the deputies.  Civil Service Commission denied the request.  The deputies subsequently sought court help in compelling the  county to conduct a name clearing due to the CLERB findings.  

After some litigation, appeals court ruled that although the deputies were not entitled to liberty interest hearings, they were entitled to an administrative appeal under the California Public Safety Officers Procedural Bill of Rights Act (PSOPBRA).  The matter was remanded to the county to establish a hearing procedure.  The county then adopted rules which  placed the burden of proof on deputies in challenging CLERB rulings and also permitted the hearing to be closed to the public without the consent of the deputies.  The deputy’s union challenged these procedures and the trial court found that the burden of proof requirement and the holding of closed hearings were improper.  County appeals.

HELD:  The deputies in this case did not suffer sufficient harm so as to warrant protection under the Constitution.  However, the evidence indicates that the CLERB’s findings did impair the deputies’ ability to obtain promotions, and, therefore, the PSOPBRA gives deputies the right to administrative review.  While the precise details of the procedures under this state statute are left to local law enforcement agencies, the law is clear that the administrative appeal requires an independent re-examination of the matter.  At a minimum, the re-examination must be conducted by someone who has not been involved in the initial determination.  It is axiomatic in the law that in disciplinary proceedings the burden of proving a charge rests upon the party making the charge.  Thus, placing the burden of proof on the deputies is contrary to basic legal principles and California statute.  

Similarly, since the CLERB findings are placed in the public arena, the deputies also have a substantial interest in receiving any vindication in a proceeding that is also open to the public.  A reversal of a CLERB finding that occurs in a closed hearing would not give members of the public the same level of confidence as a proceeding which was fully open to them and in which they had complete access to contradictory evidence offered by a deputy.  Thus, closed hearings would not provide deputies with the full vindication they seek.  The county has not articulated any reason to support the closing of the hearings.  Because the deputies have an obvious interest in a public hearing, California statute requires that these hearings be held in the open.  Affirmed for deputies.  [Caloca v. County of San Diego, 126 Cal. Rptr.2d 3 (Cal. Ct. App. 2002)]

Sick leave

The city and the Fraternal Order of Police (FOP) were parties to a collective bargaining agreement.  One provision allowed retiring and resigning officers to have a certain portion of their accumulated sick leave converted into cash upon separation from service.  The contract provision stated that the separating officers would be paid their regular salary rate for all accumulated leave up to a maximum of the equivalent of three months pay.  Several retiring officers sought sick pay for ninety days.  However, city paid them for only sixty days.  The city arrived at the figure by dividing the annual salary by twelve and multiplying that amount by three.  Even though one could argue that there are only twenty working days in a calendar month, the city stood firm that the employees’ salary was based on annual wage.
 
The FOP, however, argued that a month is twenty working days for the purposes of calculating the value of this type of sick leave.  Consequently, the FOP argued that the individual should have been paid for ninety actual days of sick time.  Thus, the city took the position that the payment should be based on a calendar basis while the FOP argued actual work days.  

Subsequently, the union and the FOP signed off on a tentative agreement that recognized that ninety days of sick pay was equal to three months of full pay, not sixty days.  FOP contends that this provision resolved the matter, but the city’s position was that the paragraph was negotiated as part of a successor agreement that was inapplicable to the current claims.  The city steadfastly refused to disregard the traditional calendar and accept that a month was twenty days as asserted by the FOP.  

Ultimately, the matter went before an arbitrator.  The arbitrator sided with the FOP and ordered the city to pay the equivalent of ninety full days of accumulated sick leave.  The arbitrator, in finding that the agreement was ambiguous, referred to the tentative successor agreement to help explain the intent of the parties.  City went to court to vacate the arbitrator’s award claiming that the order exceeded the arbitrator’s authority.   Trial judge reversed the arbitrator’s decision.  FOP appeals.

HELD:  Under Illinois law, a court’s review of an arbitrator’s award is extremely limited.  This narrow scope of review is a reflection of the legislature’s intent in providing finality for labor disputes submitted to arbitration.  Arbitration awards should be construed whenever possible so as to uphold their validity.  The scope of an arbitrator’s power generally depends upon what the parties agreed to submit to arbitration.  If an award is within the submission and contains the honest decision of an arbitrator, the court will not set it aside for error of law or fact.  Indeed, a court may not reverse an arbitrator’s decision simply because it is contrary to the manifest weight of the evidence.  

The resolution of this case depends on what constitutes three month’s pay.  The FOP champions the “actual work theory” while the city advocates the monthly pay approach.  An employee would be entitled to less payout under the city’s calendar basis theory than under the FOP’s actual work theory.  The contract in this case is ambiguous, as the arbitrator found.  It is axiomatic that a court’s principal goal in construing a contract is to give effect to the party’s intent at the time they entered the contract.  The arbitrator specifically found that the new tentative agreement became necessary to explain what was intended between the parties.  The arbitrator found that the tentative agreement was a negotiated settlement of the grievance between the parties.  The settlement was clear and enforceable.  There is no basis for concluding that the arbitrator is unable to accept a properly negotiated agreement that resolves the issue between the parties.  Since the arbitrator, therefore, was acting within the scope of his authority in conducting the settlement, the trial court erred in not upholding the award.  Reversed, reinstating ninety calendar days of sick pay to officers.  [City of Northlake v. Illinois Fraternal Order of Police Labor Council, Lodge 18, 775 N.E.2d 1013 (Ill. App. Ct. 2002)]

Substance abuse testing

In 1991, Bagnola, a police officer, was ordered to provide a urine specimen for drug testing.  Consistent with department rules, he provided two specimens, A and B, which were placed in separate bottles.  Bagnola was unable to provide enough urine to fill both bottles at the same time.  So, after filling bottle A, he drank some water and waited thirty-five minutes before providing the second bottle.  

Under department procedures, a private laboratory was used for the testing.  Bottle B remained with the department for testing by a laboratory of the officer’s choice if bottle A tested positive.  Indeed, in this case, sample A tested positive and Bagnola was so notified.  He requested the department send bottle B to the lab for testing.  This specimen also tested positive for cocaine, although at a lower level.  Administrative charges were brought against Bagnola seeking his dismissal.  

Ultimately, Bagnola requested both urine specimens A and B only to be told they had been destroyed.  The destruction had occurred even though the time limit for maintenance of the samples as specified in the contract between the city and the lab had not expired.  Bagnola’s efforts to have the hearing board drop the charges were unsuccessful.  Rather, the board upheld the termination, finding that Bagnola had a full opportunity to test the B bottle and had done so with it also producing a positive finding of cocaine.  The board concluded that the presence of cocaine in the urine was conclusive evidence of illegal possession of cocaine.  Sub-sequent litigation ensued involving appeals of the dismissal.  Ultimately, his termination was affirmed.  Bagnola, during this time, filed a civil suit against the city and the laboratory for negligent spoilage of evidence.  City and lab move for summary judgment on the grounds that the city had no duty to preserve the specimens and that the suit was barred by the doctrine of res judicata.  Trial court granted summary judgment for city and former officer appeals.
HELD:  The doctrine of res judicata is similar to the concept of double jeopardy but applies in civil matters.  The concept bars relitigation of claims for issues previously decided.  Under the doctrine of res judicata, the judgment in the first suit is conclusive not only on the matters actually decided but also on all issues that could have been decided during that suit.  The doctrine of res judicata applies when three criteria are met:  (1) there is a final judgment on the merits rendered by a court of competent jurisdiction; (2) there is an identity of cause of action; and (3) there is an identity of parties.  A review of this case reveals that all three elements are met.  The spoilage suit and the administrative review of the dismissal satisfy the same transaction test for res judicata purposes.  
Here, both suits arose out of a single group of facts from the same incident.  There is an identity of cause of action and identity of parties involved.  A final judgment was entered in the earlier administrative action and, as such, is binding on the former police officer.  Hearing board determined that the destruction of the evidence did not prevent Bagnola from having the full opportunity to test the second specimen.  Since the sole basis of his discharge was possession of cocaine and the tests results constitute primary evidence establishing that possession, the board’s determination of the results were accurate and did not prejudice the former officer’s ability to defend himself.  The judgment in the first proceeding was conclusive to this cause of action and bars the former officer from asserting a spoilage claim against the city and the lab.  Summary judgment affirmed.  [Bagnola v. SmithKline Beecham Clinical Laboratories, 776 N.E.2d 730 (Ill. App. Ct. 2002)]

Dismissal procedures

The Kentucky Constitution creates the office of county sheriff, but is silent as to the power of that office to employ or remove deputies.  Pursuant to an act of the legislature, counties are granted authority to pass an ordinance creating a deputy sheriff board which is charged with the duty of holding hearings in disciplinary matters concerning deputies.  In 1998, a sheriff terminated McClure’s employment as a deputy.  McClure requested a hearing before the county merit board.  Before the hearing could be held, however, the sheriff sought an injunction to stop the hearing.  Trial court concluded that the deputy sheriff merit board statute violated the Kentucky Constitution relative to the authority of sheriffs.  An intermediate appellate court upheld the decision, finding that the dismissal of deputies is the exercise of executive power by an independently elected officer that the legislature cannot usurp without offending the state constitution.  County appeals.  

HELD:  While the state constitution creates the office of sheriff, it is silent on the question of removal of deputies.  Thus, the sheriff has no constitutional right of either appointment or removal.  Rather, Kentucky statute creates the power to appoint deputies and an implied common law authority to remove deputies at will.  Prior law holds, however, that the legislature may take common law powers away from executive constitutional officers and assign them to different executive officers or agencies without violating the state constitution.  Such is what happened in this case.  In enacting the deputy sheriff merit board statute, the legislature permitted the county to transfer the executive power of removal from the sheriff to another body (the merit board), an administrative agency acting in an executive capacity.  While the sheriff had common law authority to remove McClure at-will, that authority must yield to the superior policy of legislative enactment.  Reversed for deputy sheriff.  [McClure v. Augustus, 85 S.W.3d 584 (Ky. 2002)] 

Layoffs

The borough was a beach community that traditionally hired special police officers to assist during the summer months.  Faced with a budget crisis in early 2001, the borough applied to the state for permission to lay off several permanent employees, including eight police officers.  The plan was approved with a scheduled lay off date of May 31.  The police union claimed that the layoff was motivated by bad faith rather than economic concerns and filed an appeal.  Meanwhile, the borough announced its intention to hire special officers for the summer season.  

In past years, the borough had hired about ten officers during the summer time to supplement the  regular force.  New Jersey law authorized resort communities to hire special law enforcement officers on a temporary basis.  These officers received a salary but not the same benefits as regularly employed police officers.  State law created two classes of these officers: Class I officers that were authorized to perform traffic and crowd control and issue summons and Class II which were authorized to perform all the duties of a regular police officer.  The borough intended to hire Class II officers, just as it had in previous years.  The police union challenged this effort because the state statute, which authorized the hiring of the special law enforcement officers, specifically prohibited their use to diminish or replace full-time officers employed by the community.  Merit board found for union and city appeals.

HELD:  The central issue in this case is whether summer hiring by a resort community of  seasonal officers while there are regular officers are on layoff status automatically violates the statutory prohibition based solely on the existence of the layoff list.  Obviously, the Class II special officer technique is vulnerable to abuse as a device for replacing regular officers.  The statute can be deemed to be violated only when the hiring of the special officers is intended to and actually results in a substitution of special officers for regular officers.  This determination must be made on a case-by-case basis considering all relative circumstances.  A resort community’s decision to reduce its regular year-round police for economic reasons is authorized by New Jersey law when approved by the state.  This decision does not affect its need for enhanced law enforcement services during the summer season.  Since the period of service of special officers is seasonally limited by statute, it is plain that they cannot realistically be regarded as replacing or substituting for regular year round officers.  If that were so, then the statute would effectively be interpreted as barring the hiring of special officers from Memorial Day to Labor Day.  Such is not the intent of the statute.  Reversed for city.  [In the matter of special police officers, Borough of Keansburg, 806 A.2d 834 (N.J. Super. Ct. App. Div. 2002)]

Dismissal procedures

Under Wisconsin law, appeals of police disciplinary and dismissal actions go to the police and fire commission (PFC).  The PFC is composed of an impartial body that operates independently of the city itself.  By state statute, the PFC is to be composed of five citizen members who have no direct interest in the outcome of a case.  Appointment of citizens is designed to prevent the board from operating as an agent of a city official or the police or fire chief.  Statute mandates that the board operate independently.  Heil, a police officer, had numerous administrative charges brought against him.  At the hearing before the PFC, sitting with the PFC was an individual who the mayor had appointed to be liaison with the PFC.  This individual was present throughout most of the hearing and sat in on the PFC deliberations.  He participated fully in the hearing except that he did not vote or sign the decision.  The PFC characterized him as a non-voting observer and resource.  After the hearing and deliberations, the PFC discharged Heil.  Heil appealed the dismissal.  Trial court on appeal decided that the liaison’s presence tainted the proceedings.  The court ultimately ordered a new hearing.  PFC appeals.

HELD:  The PFC argues that the liaison’s mere presence was a formal error but did not result in actual prejudice or impropriety.  However, the practice of having a council liaison to the PFC is not a reasonable local adaptation to the state statute.  While the liaison’s presence may not infringe on the statutory authority of the five PFC members, it does infringe on the officer’s right to due process - his right to be judged by an impartial board.  Whenever a particular power or duty is delegated to a body, that body must perform that duty and if others who have no right to act join in its performance, the act is void.  PFC has been granted the power to decide charges brought against police officers.  The statute mandates an independent board.  The liaison sitting with the panel unquestionably diminishes the appearance of the board’s independence.  As a representative of the council and the mayor who supervise the police chief, there is sufficient appearance of impropriety to taint the entire proceeding.  Hearing determination was void.  Affirmed for dismissed police officer.  [State of Wisconsin ex rel. Heil v. Green Bay Police and Fire Commission, 652 N.W.2d 118 (Wis. Ct. App. 2002)]

Settlements

Annapolis, Maryland

police officers

Members of the bargaining unit of the Annapolis Police Department recently inked a new contract that will provide an immediate 11.1 percent wage hike. The boost will move base starting pay to $35,000 a year. The one-year pact with Local 400 of the United Food and Commercial Workers, AFL-CIO, will provide many veteran officers with wage hikes of more than $3,500 annually. The pay boost is in response to a campaign promise by Mayor Ellen O. Moyer to improve wages in order to reduce employee turnover. The department has 115 officers, about twenty short of authorized staffing.

Chico, California

police officers

Chico, California, police officers are set to get a nearly 20 percent pay raise for 2002, plus more than $120,000 in city contributions to offset health insurance costs. The Chico City Council unanimously approved the agreement with the officers' union, the Chico Police Officers' Association. Pay raises for 78 police officers will total almost $1 million this year. Under the agreement, police officers will receive a nine percent pay increase retroactive to June 30. An additional 10 percent pay increase is expected to take effect December 29. Chico's 68 police officers' current pay range runs between $17.23 and $23.09 per hour. The department's ten sergeants make between $24.36 and $28.20 per hour. In an unusual contract provision, the method of determining pay raises shifts away from city-union bargaining. Future raises will be based on increases in city revenue. The city will compare revenue receipts for the last fiscal year against those of the fiscal year before. If revenue increases, police officers' pay will increase. If revenue remains constant or decreases, police officers will not take a pay cut, but also will not receive a pay increase. The agreement with the Chico Police Officers' Association is effective through 2007.

Euclid, Ohio

police officers

A four-year deal between the City of Euclid and its police officers represented by Lodge 18 of the Fraternal Order of Police was agreed to just before Christmas. The contract freezes wages for 2002 but provides a 4.5 percent pay hike in 2003 and four percent boosts in both 2004 and 2005. The pact, which is retroactive to January 1, 2002, covers 98 police officers.

New Orleans, Louisiana

police officers

For the first time in three years New Orleans police officers will be seeing a pay hike. The boost comes as part of an across-the-board pay hike for all city employees. While most municipal workers will gain a five percent raise, boosts in the police department will be on a sliding scale. Starting pay for recruits goes to $28,696 thanks to a 12.5 percent raise. Rookie patrol officers will receive $31,566 while top of scale will hit $40,807. Sergeants will gain a 7.5 percent boost in base pay, bringing their base salary to $38,828. New Orleans officers also receive a pay supplement from the state. Uniform allowance was boosted to $500 annually. In order to reduce turnover of young officers, new recruits will now be asked to sign a three-year contractual commitment to the department. Personnel departing before the end of the three-year commitment must reimburse the city $10,000 for each remaining year.