City of Allentown v. Int'l Assoc. of Firefighters
City of Allentown v. Int'l Assoc. of Firefighters - No. 24 MAP 2016
| Pa. | Mar 28, 2017Background
- City of Allentown and IAFF Local 302 dispute an Act 111 interest-arbitration award requiring a minimum of 25 firefighters per shift and excluding overtime from pension calculations.
- Arbitration panel (initial and reaffirmed on rehearing) reduced minimum per-shift complement from 28 to 25 and adjusted pension salary basis after finding the City’s pension funding situation "critically onerous."
- City sought judicial relief arguing the award unduly infringed its managerial prerogatives by impairing its ability to address an unfunded pension liability.
- The arbitration panel found the City’s financial evidence persuasive but concluded the award balanced safety concerns and the City’s fiscal needs and declined to modify the July 11, 2012 award.
- The Supreme Court affirmed that the City was not entitled to relief, with Justice Saylor concurring separately to emphasize deference to the arbitration panel’s fact-findings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the arbitration award mandating 25 firefighters per shift is beyond managerial prerogative | City: the minimum staffing unduly constrains managerial control and worsens the pension crisis | Union: the staffing requirement concerns working conditions and is a bargainable subject; award balances safety and fiscal concerns | Court: award does not unduly infringe managerial prerogatives; no relief granted |
| Whether the City’s fiscal/pension crisis justifies modifying or vacating the award | City: severe pension shortfall required greater relief; evidence warranted judicial intervention | Union: panel considered fiscal evidence and crafted adjustments; panel’s decision should be respected | Court: defer to panel’s judgment; panel reasonably balanced pension impact and safety; City not entitled to modification |
| Proper scope/standard of narrow certiorari review of Act 111 awards | City: courts may review awards that exceed arbitrators’ powers when awards impinge managerial functions | Union: courts should be constrained and defer to arbitrators’ fact findings | Court: affirms limited/narrow certiorari but engages in some fact-sensitive balancing; concurrence urges maximal deference to panel fact-finding |
Key Cases Cited
- Borough of Ellwood City v. Pa. Lab. Rels. Bd., 606 Pa. 356, 998 A.2d 589 (2010) (case-specific inquiry on whether an ordinance or action affects terms and conditions of employment)
- City of Philadelphia v. IAFF, Local 22, 606 Pa. 447, 999 A.2d 555 (2010) (test whether an award unduly infringes managerial prerogatives)
- Moon Twp. v. Police Officers of Moon Twp., 508 Pa. 495, 498 A.2d 1305 (1985) (review under excess-of-powers rationale; categorical rule for residency requirement)
- Washington Arbitration Case, 436 Pa. 168, 259 A.2d 437 (1969) (foundation for narrow certiorari review limiting arbitrators to terms and conditions of employment)
- Cnty. of Allegheny v. Allegheny Cnty. Prison Emps. Indep. Union, 476 Pa. 27, 381 A.2d 849 (1977) (deference to arbitrators where arbitrability has been found)
- PSP v. PSTA (Betancourt), 540 Pa. 66, 656 A.2d 83 (1995) (interest arbitration awards must concern terms and conditions of employment)