State Employment Relations Bd. v. Youngstown
2021 Ohio 4552
| Ohio Ct. App. | 2021Background
- Sept 3, 2019: Youngstown Professional Firefighters (Union) filed an unfair labor practice (ULP) complaint with SERB; SERB found probable cause on Oct 31, 2019.
- Nov 2019: City enacted Ordinance 19-336 to abolish three Youngstown Fire Department Battalion Chief positions by attrition.
- Dec 18, 2019: SERB petitioned the Mahoning County Common Pleas Court for immediate injunctive relief to preserve the contractual status quo (prevent elimination of the three positions); the Union intervened.
- Jan 21, 2020: Trial court granted SERB’s requested injunction, enjoining the City from eliminating the three Battalion Chief positions pending SERB’s final order.
- Mar 2, 2020: Magistrate found the City in contempt for violating the injunction and ordered the City to promote a qualified candidate to a vacant Battalion Chief position by April 15; the City objected.
- Jun 9, 2020: Trial court overruled the City’s objections, adopted the magistrate’s decision, and entered judgment finding the City in contempt; the City appealed. (SERB issued a final order on Jun 11, 2020, but that occurred after the appealed judgment.)
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether contempt finding was moot after SERB issued a final order | SERB: contempt valid based on City’s pre-injunction violation; post-judgment SERB action does not affect contempt already entered | City: SERB’s final adjudication superseded the court’s injunction, so contempt became moot and court lost enforcement jurisdiction | Court: Events after the Jun 9 judgment (SERB’s Jun 11 order) are irrelevant; contempt ruling on Jun 9 not moot and affirmed |
| Whether trial court abused its discretion in issuing the January 21 injunction | SERB: authorized to seek temporary injunctive relief to preserve status quo pending final adjudication | City: SERB lacked standing/authority to seek injunctive relief on behalf of the Union; court exceeded its statutory authority and abused discretion | Court: Statute authorizes SERB to seek temporary relief; court’s injunction to preserve status quo was proper and not an abuse of discretion |
Key Cases Cited
- State ex rel. Ventrone v. Birkel, 65 Ohio St.2d 10 (1981) (abuse-of-discretion standard for reviewing contempt findings)
- Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (abuse-of-discretion defined as unreasonable, arbitrary, or unconscionable)