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

• The Union, representing Bernalillo County Correction Officers’ Association (BCCOA), filed a lawsuit to enforce a grievance settlement with the County for wage increases, following a collective-bargaining agreement (CBA) that included a lockstep clause. This clause stipulated that BCCOA members would receive wage increases if any other County employee did. Despite a grievance being sustained by the Chief of Corrections, the agreed wage increases were not implemented, leading to the Union's legal action (paras 2-3).

Procedural History

• AFSCME Local 2499 v. Bd. of Cnty. Comm’rs of Bernalillo Cnty., No. 34,431, mem. op. (N.M. Ct. App. Sept. 1, 2015) (non-precedential): The case had previously gone through three years of litigation and one jurisdictional appeal before reaching the current appeal stage (para 4).

Parties' Submissions

• Union: Argued that the County's refusal to implement wage increases despite a grievance settlement violated the terms of the CBA. The Union also contended that the Public Employee Bargaining Act (PEBA) did not apply to the County due to a grandfather clause, and thus, the grievance settlement was enforceable (paras 5, 8-9).
• County: Contended that the grievance settlement was unenforceable due to statutory limitations on the expenditure of funds as outlined in PEBA and the Bateman Act. Additionally, the County argued that the Chief of Corrections lacked the authority to grant a wage increase, making the grievance settlement unenforceable (paras 4, 16, 19).

Legal Issues

• Whether the district court erred in applying Section 10-7E-17(E) of the PEBA to the grievance resolution, given the County's grandfathered status under a collective bargaining ordinance (para 8).
• Whether the grievance settlement was enforceable under the terms of the CBA, despite the County's argument that the Chief of Corrections lacked authority to grant a wage increase (para 19).

Disposition

• The Court of Appeals reversed the district court’s grant of summary judgment in favor of the County and remanded the case for further proceedings (para 23).

Reasons

• The Court of Appeals, consisting of Judges Megan P. Duffy, Jennifer L. Attrep, and Kristina Bogardus, unanimously found that the district court erred in its application of PEBA to the grievance resolution due to the County's grandfathered status under a collective bargaining ordinance. The Court clarified that the PEBA's requirements, including those related to the appropriation and availability of funds, did not apply to the County because of its grandfather clause. Furthermore, the Court rejected the County's argument that the Bateman Act precluded enforcement of the grievance resolution, noting the County failed to demonstrate a violation of the Act. The Court also affirmed that the grievance resolution complied with the terms of the CBA, holding that the Chief of Corrections had the authority to resolve the grievance as per the CBA's procedures (paras 8-22).