Lancaster County v. Pennsylvania Labor Relations Board
626 Pa. 70
| Pa. | 2014Background
- Since 1975 AFSCME District Council 89 was certified to represent a bargaining unit that included prison guards and maintenance employees; the County and Union later negotiated multiple CBAs but did not negotiate specifically over Maintenance Mechanic I/II positions.
- In November 2009 Lancaster County centralized county maintenance under a Facilities Management Department; two days later the Union petitioned the PLRB to clarify that Maintenance Mechanic I/II positions belong in the prison-guards unit.
- A PLRB hearing examiner and the Board found Maintenance Mechanics supervised inmates on outside work details, were the only employees watching inmates outside the walls, could sound alarms, prevent theft of tools, discipline or secure inmates, and thus were part of the prison security apparatus — so they are "guards at prisons" under PERA § 604(3).
- A divided Commonwealth Court reversed, holding Maintenance Mechanics’ primary role was maintenance (not inmate security): they lacked guard training, did not perform searches, handcuffing, escapes, or man guard posts, and supervised inmates only in a work-release-like capacity.
- The Pennsylvania Supreme Court granted review to decide whether the Board’s interpretation of "guards at prisons" was clearly erroneous and whether the Commonwealth Court afforded proper deference to the Board’s findings.
Issues
| Issue | Plaintiff's Argument (County) | Defendant's Argument (PLRB/Union) | Held |
|---|---|---|---|
| Whether "guards at prisons" under PERA §604(3) includes maintenance employees who supervise inmates on outside work details | Maintenance Mechanics’ primary duties are maintenance; occasional supervision does not make them guards; primary-responsibility test governs; no guard training or authority to enforce custody | The Board’s longstanding construction includes employees responsible for inmate security or who are a vital cog in prison security even if not full-time corrections officers | Maintenance Mechanics are "guards at prisons": Court defers to Board’s broad, consistent interpretation and finds substantial evidence supporting Board’s factual findings |
| Proper standard of review for PLRB unit determinations | Agency interpretation not controlling where statute undefined; appellate court may review de novo whether employees are guards | Agency expertise in labor relations and prior consistent administrative interpretations merit controlling deference unless clearly erroneous | Apply deferential review: agency interpretations receive controlling weight absent clear error; Commonwealth Court erred by substituting its judgment for the Board |
| Whether the Board’s factual findings were supported by substantial evidence | Many Board findings contradicted record (e.g., guards still monitored inmates; mechanics lacked authority to restrain or discipline) | Evidence showed mechanics supervised inmates alone outside walls, could sound alarms, prevent tool theft, discipline, and occasionally break up fights | Board’s factual findings were supported by substantial evidence; conclusions reasonable and not arbitrary |
| Consequences of classification (policy) — should maintenance mechanics be precluded from striking as guards? | Inclusion would unduly broaden strike prohibition to many non-security roles; county could fill maintenance or hire replacements without harming prison security | Permitting strikes by employees who supervise inmates risks safety, interrupts sentencing-related programs and work-release obligations; safety policy favors broad guard definition | Legislative purpose and safety concerns support a broad interpretation to exclude such positions from units with other public employees |
Key Cases Cited
- Borough of Ellwood City v. PLRB, 998 A.2d 589 (Pa. 2010) (appellate review standard for agency factual findings and deference to agency expertise)
- Nazareth v. PLRB, 626 A.2d 493 (Pa. 1993) (deference to Board in labor-relations matters)
- Vlasic Farms, Inc. v. PLRB, 777 A.2d 80 (Pa. 2001) (deference to Board’s reasonable and longstanding statutory construction in unit determinations)
- Commonwealth Office of Admin. v. PLRB, 916 A.2d 541 (Pa. 2007) (limits of agency interpretation when inconsistent with unambiguous statute)
- Lancaster County v. PLRB, 85 A.3d 73 (Pa. Cmwlth. 2012) (Commonwealth Court decision reversing the Board below)