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Keywords

arbitrationappealdeclaratory judgment

arbitrationappellantappelleedeclaratory judgment

Related Cases

Board of Education of Prince George’s County; Administrator, Wage and Hour Division v.

Facts

Public safety employees in Anne Arundel County challenged the County Council's legislative restrictions on collective bargaining regarding health insurance benefits. The County Council had enacted Bill 85-13, which excluded health insurance benefit options from collective bargaining and arbitration. The employees filed a declaratory judgment action after the County Administrator declined to negotiate these benefits, arguing that the County Council exceeded its authority. The circuit court ruled in favor of the County, leading to the appeal.

After the County Administrator, relying on the new law, declined to negotiate employee health insurance benefit options and plans, aggrieved members of the public safety unions affected by Bill No. 85-13 ('Appellants') filed a declaratory judgment action in the Circuit Court for Anne Arundel County against Anne Arundel County ('County' or 'Appellee'). Appellants alleged that the County Council exceeded its legislative authority in enacting Bill 85-13.

Issue

Whether health insurance benefits were subject to the mandated bargaining and arbitration process under Anne Arundel County, Md., Charter 811 and 812.

Rule

The Charter's mandate encompasses public safety employees' health insurance benefits, and 'terms and conditions of employment' is a term of art that includes health insurance benefits.

The Charter's mandate was broad enough to encompass public safety employees' health insurance benefit; 'terms and conditions of employment' was a term of art that included health insurance benefits.

Analysis

The court determined that the circuit court incorrectly concluded that the county council had exclusive authority to define 'terms and conditions of employment.' The court held that the Charter's provisions required collective bargaining and arbitration to include health insurance benefits, thus invalidating the provisions of Bill 85-13 that limited these rights.

We hold that under Charter 811 and 812, the terms and conditions of employment are subject to the two-step process of collective bargaining and arbitration. We also hold that the circuit court erred when it decided that it was the County Council's legislative function, exclusively, to resolve any ambiguities in the phrase 'terms and conditions of employment' contained in Charter 812.

Conclusion

The court reversed the judgment of the circuit court and remanded the case for further proceedings, affirming that health insurance benefits are included in the collective bargaining process.

Accordingly, we remand the case for further proceedings.

Who won?

The public safety employees prevailed in the case because the court recognized their right to collectively bargain over health insurance benefits, which the County Council had attempted to restrict.

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