303 P.3d 1110
Wyo.2013Background
- Local 276 sued the City of Sheridan for breach of the 2010-2011 CBA, alleging the City owed step increases to five firefighters who had satisfactory evaluations.
- The 2010-2011 CBA, effective July 1, 2010 to June 30, 2011, contained a detailed pay-grade/step table but not explicit timing of step increases.
- In 2010, the City froze annual step increases for fiscal reasons, notifying employees that 5% step increases were suspended for the year.
- Local 276 Grieved five employees’ cash shortfall, asserting automatic step increases upon satisfactory performance ratings.
- The City argued the CBA was clear and discretionary, and relied on the absence of a guaranteed automatic raise and on budgetary constraints.
- The district court granted summary judgment to the City, finding the contract silent and unambiguous, and thus not allowing extrinsic evidence; Local 276 appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the step increases clause ambiguous, warranting extrinsic evidence? | Local 276 contends the clause is ambiguous about automatic step increases. | City argues the clause is unambiguous and grants discretion. | Ambiguity exists; extrinsic evidence admissible. |
| Does the City retain discretion to grant or deny step increases under the CBA? | Local 276 asserts automatic step increases for satisfactory ratings. | City contends discretion to decide whether to award increases. | Not unambiguously discretionary; interpretation favors automatic increases. |
| May past practice and handbook provisions be used to interpret the CBA's step increases? | Local 276 relies on prior conduct showing automatic steps. | City asserts handbook and past practice are not controlling if inconsistent with the CBA. | May be used as extrinsic evidence to interpret ambiguity. |
Key Cases Cited
- Davison v. Wyoming Game and Fish Comm’n, 238 P.3d 556 (Wyo. 2010) (extrinsic evidence permissible to interpret ambiguous contract)
- Madison v. Marlatt, 619 P.2d 708 (Wy. 1980) (contract terms may be ambiguous when silent on significant points)
- Mariano v. Board of County Comm’rs, 737 P.2d 331 (Wy. 1987) (doctrine limiting contractual obligations beyond contracting authority)