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City of Hartford v. Local 760, International Ass'n of Firefighters

Citations: 6 Conn. App. 11; 502 A.2d 429; 1986 Conn. App. LEXIS 801Docket: 3552

Court: Connecticut Appellate Court; January 7, 1986; Connecticut; State Appellate Court

Narrative Opinion Summary

In this case, the defendant appealed a trial court decision vacating an arbitration award related to the suspension of a firefighter accused of bank robbery. The union representing the firefighter filed a grievance after his suspension without pay, leading to an arbitration hearing. The arbitration board determined that while the suspension was justified, its duration was inappropriate, and thus reduced it. The plaintiffs sought to vacate the award under General Statutes § 52-418, arguing that the arbitrators exceeded their authority by modifying the suspension after affirming just cause, contrary to the specific terms of the submission. The trial court agreed, finding the award exceeded the arbitrators' powers, and vacated it. The defendant contended that the court should have remanded the case for a new hearing, but the court's decision not to do so was found to be within its discretion. Ultimately, the court's ruling to vacate the arbitration award was upheld, as all judges concurred that there was no error in the trial court's judgment.

Legal Issues Addressed

Arbitrators' Authority under Collective Bargaining Agreements

Application: The court determined that arbitrators exceeded their authority by modifying the suspension after affirming just cause, which was not permitted under the terms of the submission.

Reasoning: The court ruled that by reducing the suspension after affirming just cause, the board exceeded its authority, thus vacating the award.

Judicial Review of Arbitration Awards

Application: The judicial review is limited to ensuring the award conforms to the submission, and the court may vacate if arbitrators exceed their powers or fail to make a definitive award.

Reasoning: The court's authority to vacate an award is limited to instances where arbitrators exceed their powers or fail to make a definitive award.

Remanding Cases for Rehearing

Application: The trial court's decision not to remand the case for rehearing was upheld as it was within the court's discretion under General Statutes § 52-418 (b).

Reasoning: The defendant's claim that the trial court erred by not remanding the case for rehearing lacks merit, as General Statutes § 52-418 (b) grants the court discretion in such decisions, which was not abused in this instance.

Scope of Arbitration Proceedings

Application: Arbitration proceedings must adhere strictly to the issues specified in the submission, with no extraneous matters allowed in the award.

Reasoning: The arbitration proceedings are strictly governed by the issues specified in the submission, with no extraneous matters permitted in the award.