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In re the Arbitration between Schenectady Police Benevolent Ass'n

Citations: 224 A.D.2d 908; 638 N.Y.S.2d 795; 1996 N.Y. App. Div. LEXIS 1526

Court: Appellate Division of the Supreme Court of the State of New York; February 28, 1996; New York; State Appellate Court

Narrative Opinion Summary

In the case at hand, an appeal was filed concerning the Supreme Court's order, which confirmed an arbitration award in favor of the petitioner, who contested a decision by the respondent's police department under a collective bargaining agreement. The dispute centered around the abolition of the 'investigator' position and the creation of a 'detective' role, to be filled by officers through competitive examination after 18 months of investigative service. The petitioner argued this action violated their agreement. Following the Mayor's denial of the grievance, arbitration was initiated, resulting in a ruling that favored restoring the status quo, which the petitioner sought to enforce through a CPLR article 75 proceeding. Despite the respondent's attempt to vacate the award, the Supreme Court confirmed it. On appeal, the court upheld the arbitration award, stating that it did not breach public policy, as the decision merely reinstated the status quo without contravening civil service laws. Allegations of arbitrator bias were dismissed, leading to an affirmation of the Supreme Court's order, with costs awarded to the petitioner.

Legal Issues Addressed

Allegations of Arbitrator Bias

Application: The court dismissed claims of bias against the arbitrator due to tone, emphasizing that bias must be substantiated by more than the language used in the decision.

Reasoning: The court found no merit in the respondent's claim of bias against the arbitrator based on the decision's tone.

Confirmation of Arbitration Awards under CPLR Article 75

Application: The Supreme Court's role is to confirm arbitration awards unless a strong public policy is violated. In this case, the court upheld the arbitrator's award as it did not contravene public policy.

Reasoning: The court upheld the arbitrator's award, stating that courts generally do not disturb such decisions unless there is a violation of strong public policy.

Public Policy and Civil Service Appointments

Application: The respondent's argument that the arbitration award contravened public policy by preventing merit-based appointments was rejected. The court found the decision restored the status quo without infringing on civil service law.

Reasoning: The respondent claimed that the arbitrator's ruling prevented the creation of the detective position and thus contravened public policy favoring merit-based civil service appointments. However, the court disagreed, asserting that the arbitrator's decision merely restored the status quo as per the collective bargaining agreement.