Fraternal Order of Police v. City of Evansville, 940 N.E.2d 314

FOP and City entered a 2001–2004 collective bargaining agreement governing police department staffing and holiday pay/compensation.
The agreement guarantees a 4/2 work schedule and provides holiday compensation options (comp time or overtime) for officers.
In Jan 2004 the holiday staffing policy was changed to reduce patrol holiday sergeant coverage for cost savings.
In Sept 2004 the City limited patrol sergeants to a holiday minimum staffing level (2 on Sun–Thu, 3 on Fri–Sat).
Sergeants alleged this policy violated Articles V and XX of the CBA and their holiday pay; the trial court ruled for the City after a bench trial in 2009.
FOP appeals challenging the trial court’s ruling that the City did not breach the CBA.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did City breach the CBA by enforcing the holiday minimum staffing policy?	FOP argues Four and Two implies right to holiday work/overtime.	City acts under Management Rights; no guarantee to work holidays.	No breach; policy authorized by Management Rights; no guarantee to holiday work.
Is the contract language ambiguous, requiring extrinsic evidence to resolve the meaning?	Ambiguity allows extrinsic evidence of parties’ intent.	Language is unambiguous; intent determined by four corners.	Language unambiguous; no implied right to holiday work.
Did the compensation scheme properly account for non-work holidays and holiday overtime?	Sergeants lost holiday overtime by not working; undercompensated.	Officers are paid as if on 4/2; no guaranteed overtime for holidays.	Officers paid per policy; no guaranteed holiday overtime.

Whitaker v. Brunner, 814 N.E.2d 288 (Ind.Ct.App.2004) (contract interpretation governed by four-corners; ambiguity leads to extrinsic evidence)
Bowyer v. Ind. Dep’t of Natural Res., 882 N.E.2d 754 (Ind.Ct.App.2008) (two-tier standard of review under Indiana Trial Rule 52(A))
Bailey v. Mann, 895 N.E.2d 1215 (Ind.2008) (contract interpretation to determine parties’ intent)