AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• In fiscal year 2009, the State of New Mexico implemented salary increases for its classified employees that differed from those required by collective bargaining agreements previously executed with the American Federation of State, County, and Municipal Employees, Council 18 (AFSCME) and Communication Workers of America (CWA). The Unions filed grievances, which were submitted to arbitration. The arbitrators found in favor of the Unions, determining that the State's pay package violated the terms of the agreements (paras 1, 6-10).

Procedural History

• District Court of Bernalillo County: Confirmed the arbitration awards in favor of the Unions.
• Court of Appeals of New Mexico: Affirmed the district court's confirmation of the arbitration awards.

Parties' Submissions

• State: Argued that the district court employed an improper standard of review and that the arbitrators acted in excess of their authority by determining that the Legislature appropriated sufficient funds to cover the salary increases mandated by the agreements and by issuing awards that allegedly require retroactive salary increases in violation of the New Mexico Constitution and the Public Employee Bargaining Act (PEBA) (paras 12-13, 20-27).
• Unions (AFSCME and CWA): Argued that even if the funding appropriated by the Legislature was insufficient to give all classified employees the two salary increases contracted for under the Agreements, there were nonetheless sufficient funds appropriated to fully fund the increases for Union-represented employees and still provide an “average” of two and four-tenths percent and an additional “average” of one-half percent in salary increases for all employees. They also alleged that the State Personnel Office had negotiated in bad faith (paras 6-7).

Legal Issues

• Whether the district court applied an improper standard of review in confirming the arbitration awards.
• Whether the arbitrators exceeded their powers under the UAA by determining that the Legislature appropriated sufficient funds to cover the Agreement salary increases and by mandating remedies that allegedly violate provisions of the PEBA and the New Mexico Constitution (paras 12-13).

Disposition

• The Court of Appeals affirmed the district court's confirmation of the arbitration awards in favor of the Unions (para 39).

Reasons

• The Court of Appeals held that the district court applied the correct standard of review, consistent with the Uniform Arbitration Act (UAA) and New Mexico case law, which limits review of arbitration awards to allegations of fraud, partiality, misconduct, excess of powers, or technical problems in the execution of the award. The Court found that the arbitrators did not exceed their powers as they ruled on matters within the scope of the arbitration agreement and their decisions were not in violation of the PEBA or the New Mexico Constitution. The Court also noted that the arbitrators determined that the Legislature had appropriated sufficient funds for the State to meet its contractual obligations under the Agreements, and thus, the State's failure to distribute the funds according to the terms of the Agreements was a breach of its contractual obligations (paras 13-37).