Town of North Providence v. Local 2334, International Ass'n of Firefighters
Docket: No. 97-476-A
Court: Supreme Court of Rhode Island; November 5, 1998; Rhode Island; State Supreme Court
On October 13, 1998, the Supreme Court reviewed the appeal of Local 2334, International Association of Firefighters of North Providence against a Superior Court order that confirmed an arbitration award. The case arose after a 1995 grievance filed by the union, claiming that the town violated the Collective Bargaining Agreement (CBA) by refusing to deduct union dues from the newly appointed fire chief's pay. The union contended that, despite the chief's managerial role and the 1974 Labor Relations Board certification excluding the chief from the bargaining unit, the CBA required the chief to pay union dues under Article I, Section 2(B). The arbitrator sided with the union, ruling that the town's exemption of the chief from dues payments violated the CBA and ordering the town to pay past dues. The town subsequently filed motions to vacate and stay the arbitration award, which were denied by the trial justice, who nonetheless altered the award's meaning. He indicated that the award merely permitted chiefs to opt for dues withholding without imposing any past dues obligations. The union appeals this modification, arguing that the trial justice exceeded his authority and seeks the reinstatement of the original arbitration award. The court disagrees with the union's position and agrees with the trial justice's interpretation of the arbitration award, specifically regarding the exclusion of the fire department chief from union membership. It emphasizes that including the chief, who holds a managerial and supervisory role, contradicts public policy and the intent of the National Labor Relations Act, which excludes managerial employees from collective bargaining. The court cites precedent, arguing that allowing managers and supervisors in unions creates conflicts of interest and skews bargaining power. Although there is a past case where a police chief was allowed union membership due to specific statutory language and limitations on managerial power, the court distinguishes that situation from the fire chief's case. The court concludes that permitting the fire chief's union membership would lead to an appearance of impropriety and an imbalance in bargaining power. Consequently, the court denies the appeal, affirms the judgment that nullifies parts of the arbitration award, and states that the trial justice should have vacated the award entirely. The case is remanded to the Superior Court for appropriate judgment.