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Decisions Of The Board

Board Certifications

TEAMSTERS LOCAL UNION NO. 693, INTERNATIONAL BROTHEROOD OF TEAMSTERS, CHAUFFEURS, WAREHOUSEMEN AND HELPERS OF AMERICA has been certified as the exclusive representative of all full-time Heavy Equipment Operators of the Town of Smithville. All other employees are excluded. (C-5886, 9/17/09)

LOCAL 317, INTERNATIONAL BROTHERHOOD OF TEAMSTERS, CHAUFFEURS, WAREHOUSEMEN AND HELPERS OF AMERICA has been certified as the exclusive representative of all full-time and regularly scheduled part-time Motor Equipment Operator and Laborers in the Town of Otisco. The Town Highway Superintendent is excluded. (C-5883, 9/17/09)

LOCAL 264, INTERNATIONAL BROTHERHOOD OF TEAMSTERS has been certified as the exclusive representative of all full-time and regular part-time Highway Department employees employed by the Town of Leon. All other employees are excluded. (C-5898, 9/17/09)

TEAMSTERS LOCAL UNION No. 294, INTERNATIONAL BROTHERHOOD OF TEAMSTERS, CHAUFFEURS, WAREHOUSEMEN AND HELPERS OF AMERICA has been certified as the exclusive representative of all full-time Motor Equipment Operators and the Deputy Highway Superintendent in the Town of Whitehall. The Highway Superintendent, part-time employees, and clerical staff are excluded. (C-5882, 9/17/09)

UNITED PUBLIC SERVICE EMPLOYEES UNION has been certified as the exclusive representative of all fulltime employees of the Town of Schodack in the following positions: Police Officer, Sergeant, Detective Sergeant, Lieutenant and Dispatcher. The Chief of Police is excluded. (C-5891, 9/17/09)

BOCES TEACHER AIDES ASSOCIATION, NYSUT/AFT/NEA, AFL-CIO has been certified as the exclusive representative of Teachers Aides in the Rockland County BOCES. All other employees are excluded. (C-5887, 10/30/09)

TEAMSTERS LOCAL 118, INTERNATIONAL BROTHERHOOD OF TEAMSTERS has been certified as the exclusive representative of all full-time employees working for the Town of Sweden within the following job titles: Working Foreman, Heavy Equipment Operator, Motor Equipment Operator, Laborer and Automotive Mechanic. All other employees and positions are excluded. (C-5874, 10/30/09)

UNITED PUBLIC SERVICE EMPLOYEES UNION has been certified as the exclusive representative of the Assessor, Assistant to City Clerk (Legislative Aide), Assistant Operations Manager, City Water Plant Operator, City Auditor, City Engineer, Commissioner of Planning and Community Development, Deputy City Clerk, Deputy Comptroller for Financial Operations, Grants Writing Specialist, Personnel Associate, Recreation Director and Superintendent of Water and Sewer in the City of Troy. All other employees are excluded. (C-5834, 12/18/09)

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Representation

COUNTY OF WASHINGTON. The Board denied exceptions challenging a decision of the Director of Public Employment Practices and Representation (Director), voiding seven mail-ballots in a representation election. At the ballot count, the ballots were challenged by the Board agent because the return receipt ballot envelopes were not signed by the voters consistent with the explicit directions on the voter instruction sheet sent along with the ballot. The Board affirmed the Director’s decision to void the mail ballots that had been challenged. In affirming the Director, the two-member Board noted that the general practice is that unsigned ballot envelopes are challenged by the Board agent before any envelopes are opened for the ballot count with such challenges subject to a waiver by all of the parties. To ensure consistency in all future mail ballot elections, the Board directed the Director to have the parties’ waiver of the signature requirement memorialized in a written stipulation. (C-5727, 9/17/09)

CITY OF TROY. The Board denied exceptions challenging a decision of the Director, voiding three mail-ballots in a representation election because the return receipt ballot envelopes were not signed by the voters consistent with the explicit directions on the voter instruction sheet sent along with the ballot. The Board affirmed the Director’s decision for the reasons set forth in County of Washington, C-5727, decided at the same Board meeting. (C-5606, 9/17/09)

STATE OF NEW YORK – UNIFIED COURT SYSTEM. The Board affirmed a decision of an ALJ placing the title of Secretary to Judge into the District Council (DC) 37 unit concluding that employees in that title are employees of the Unified Court System (UCS) and have a community of interest with employees in the DC 37 unit. In reaching its decision, the Board concluded that while a Supreme Court Justice is the appointing authority for an individual holding a Secretary to Judge title, UCS is the employer for those non-judicial employees for purposes of the Act. (CP-1095, 10/30/09)

SACHEM CENTRAL SCHOOL DISTRICT. The Board reversed a decision of an ALJ placing the new title of school communication aide (SCA) into a clerical unit rather than a teacher aide unit. The Board concluded that the SCA title belonged in the teacher aide unit because they are responsible for operating computers, smart boards, and audio-visual equipment in the classroom like other employees in that unit. In addition, the Board found that the duties of a SCA are more directly connected to the District’s pedagogical mission than the duties of employees in the clerical unit. (C-5760, 10/30/09)

LOCAL 445, INTERNATIONAL BROTHERHOOD OF TEAMSTERS. The Board denied exceptions filed by a community college (College) to a decision of the Director dismissing, as untimely, a petition filed by the College seeking to fragment employees working in non-professional titles at the College from a county-wide unit. The College’s petition was not filed prior to the expiration of the window period set forth in §201.3 (d) of the PERB’s Rules of Procedure (Rules). The Board rejected the College’s argument that its petition was timely under §201.3(e) of the Rules because it was filed 120 days following the expiration of the agreement. The College’s argument was rejected because under §201.3(e) of the Rules the only parties who can file a certification and/or decertification petition is an employee organization other than the incumbent employee organization or one or more public employees. (C-5810, CP-1163, 12/18/09)

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Management / Confidential

NO RECENT MANAGEMENT / CONFIDENTIAL BOARD DECISIONS.

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Improper Practices

COUNTY OF WESTCHESTER. The Board affirmed the decision of an Administrative Law Judge (ALJ) concluding that the employer violated §209-a.1(d) of the Public Employees’ Fair Employment Act (Act) when it unilaterally transferred the duties associated with air transporting extradited prisoners to the United States Marshals Service (Marshals Service). In its decision, the Board rejected the County’s contention that the air transport extradition duties performed by the Marshals Service are not substantially similar to the work previously performed exclusively by unit members. In addition, the Board rejected the County’s argument that there was a significant change in job qualifications requiring the balancing of the respective interests of the parties. (U-27042, 9/17/09)

NIAGARA FRONTIER TRANSIT METRO SYSTEM, INC. The Board affirmed the decision of an ALJ dismissing a charge alleging that the employer violated §209-a.1(d) of the Act when it unilaterally changed the use and purpose of a medical examination under the terms of the parties’ collectively negotiated agreement. After providing the charging party with a full opportunity to set forth the basis for the charge during a colloquy on the record and in a subsequent offer of proof, the ALJ concluded that the employer had satisfied its duty to negotiate the subject of the charge. In its decision, the Board rejected the charging party’s assertion that the ALJ had misconstrued the allegations of the charge after reviewing the colloquy before the ALJ and the charging party’s offer of proof. In reaching its decision, the Board noted that the purpose of an offer of proof is to provide parties with an opportunity to identify facts it intends on proving at a hearing in support of a charge or in support of a defense. Finally, the Board affirmed the ALJ’s conclusion that the subject of the charge is inherently and inextricably intertwined with the negotiated terms of the parties’ agreement. (U-27133, 9/17/09)

CITY OF MIDDLETOWN POLICE BENEVOLENT ASSOCIATION. The Board affirmed, in part, a decision of an ALJ concluding that a proposed police disciplinary procedure and a proposed bill of rights were prohibited subjects of negotiations based upon the police disciplinary provisions of the city charter, which were originally enacted by the Legislature in 1942. While the subject of police disciplinary procedures is, in general, a mandatory subject of negotiations under §209-a.1(d) of the Act, the Board concluded that, based upon the Court of Appeals’ decision in Patrolmen’s Benevolent Assn of the City of New York, Inc. v New York State Pub Empl Rel Bd, 6 NY3d 563, 39 PERB ¶7006 (2006), the city charter provisions rendered the proposed police disciplinary procedure and bill of rights prohibited subjects. However, the Board concluded that the proposal is a mandatory subject for any unit members who are entitled to Civ Serv Law §75 protections, such as veterans and volunteer firefighters, consistent with the Court of Appeals’ decision in Auburn Police Local 195 v Helsby, 62 AD2d 12, 11 PERB ¶7003 (3d Dept 1978), affd, 46 NY2d 1034, 12 PERB ¶7006 (1979).

The Board also affirmed the ALJ’s holding that the proposed GML §207-c procedure ending in binding arbitration is mandatorily negotiable under both Watertown Police Benevolent Association, 30 PERB ¶3072 (1997), confirmed, City of Watertown v New York State Pub Empl Rel Bd, 31 PERB ¶7013 (Sup Ct Albany County 1998), revd, 263 AD2d 797, 32 PERB ¶7016 (3d Dept 1999), revd, 95 NY2d 73, 33 PERB ¶7007 (2000) and Poughkeepsie Firefighters’ Association, Local 596, IAFF 36 PERB ¶3014 (2003), annulled sub nom. Poughkeepsie Prof Firefighters’ Assn, Local 596, IAFF v New York State Pub Empl Rel Bd, 36 PERB ¶7016 (Sup Ct Albany County 2003), revd, 16 AD3d 797, 38 PERB ¶7005 (3d Dept 2005), affd, 6 NY3d 514, 39 PERB ¶7005 (2006) (hereinafter Poughkeepsie).

As in Watertown, the proposal in this case sought an arbitral process to resolve disputes over GML §207-c benefits while at the same time recognizing the employer’s statutory right to determine initial eligibility. In addition, the Board found the proposal to be mandatory under Poughkeepsie because it expressly proposed that the arbitrator’s scope of review would be limited to determining whether the claims manager had a reasonable basis for the eligibility determination based upon the record before him or her.

The Board rejected the employer’s argument that the proposal is nonmandatory under Poughkeepsie because it would permit the arbitrator to hear testimony and it would allow parties to issue subpoenas. The Board interpreted the subpoena provision, in conjunction with the provision permitting testimony at the arbitration, as granting the arbitrator the discretion to permit testimony by individuals whose reports were reviewed by the claims manager. In addition, the Board noted that a trial can be ordered to resolve questions of fact in an Article 78 proceeding seeking review of an administrative determination issued without a hearing. Therefore, nothing in Poughkeepsie prohibited the proposal that would grant an arbitrator the discretion to hear testimony to the same extent that a court might hear testimony in an Article 78 proceeding. (U-27423, 9/17/09)

BOARD OF EDUCATION OF THE CITY OF SCHOOL DISTRICT OF THE CITY OF NEW YORK. The Board affirmed a decision of an ALJ, in part, to the extent that the ALJ dismissed, as untimely, an allegation that the employer violated §209-a.1(d) of the Act by unilaterally transferring unit work. The Board concluded that the employee organization had actual knowledge of the transfer of unit work in the employer’s Long Island City plumbing warehouse more than four months before the charge was filed. However, the Board remanded to the ALJ the timely allegation in the charge that the employer violated §209-a.1(d) of the Act by failing to respond to the employee organization’s information request relating to the transfer of the unit work. (U-25883, 9/17/09)

INCORPORATED VILLAGE OF HEMPSTEAD. The Board affirmed a decision of an ALJ concluding that the employer violated §§209-a.1(a) and (d) of the Act by renunciating its obligations under an 18-month-old written agreement accreting certain titles to an existing collective negotiations unit. The agreement in question was a stipulation of settlement that had resolved a prior unit placement petition filed with PERB by the employee organization. Relying on County of Orange, 25 PERB ¶3004 (1992), the Board found that the employer violated §§209-a.1(a) and (d) of the Act by unilaterally altering the existing unit. In reaching its decision, the Board rejected the employer’s argument that the prior stipulation of settlement required legislative approval. (U-26139, 9/17/09)

COUNTY OF WESTCHESTER. The Board affirmed a decision of an ALJ conditionally dismissing two improper practice charges based upon the maintenance of standards clause in the parties’ collectively negotiated agreement. In reaching its decision, the Board rejected the employee organization’s argument that the ALJ allegedly misinterpreted and misapplied the applicable standard for a merits deferral and misinterpreted and misapplied the Board’s decision in County of Sullivan and Sullivan County Sheriff, 41 PERB ¶3006 (2008). (U-27815, U-27845, 9/17/09)

COUNTY OF GREENE and SHERIFF OF GREENE COUNTY. The Board reversed the decision of the Assistant Director of Public Employment Practices and Representation (Assistant Director) dismissing an improper practice charge. The Board concluded that the Assistant Director erred in concluding that the charge did not include an allegation that the joint employer violated §209-a.1(d) of the Act by failing to disclose requested information about the financial impact of the proposed health benefits concessions. Therefore, the charging party’s exceptions were granted, in part, and the case was remanded to the Assistant Director to determine the merits of that allegation. (U-27095, 10/30/09)

TOWN OF RIVERHEAD. The Board affirmed the decision of an ALJ dismissing an improper practice charge alleging that the employer violated §209-a.1(d) of the Act by unilaterally transferring certain unit work in an animal shelter to volunteers and unilaterally transferring animal shelter administrative duties to police personnel. The Board held that the charging party failed to meet its burden of establishing exclusivity over the work being performed by the volunteers. In addition, the Board found that the interests of the employer in transferring the administrative duties to police personnel outweighed those of the unit employees. (U-26552, 10/30/09)

NIAGARA CHARTER SCHOOL. The Board remanded the case to an ALJ for further processing aimed at clarifying the stipulated record with respect to an improper practice charge alleging that a charter school violated §209-a.1(d) of the Act when it refused requests to commence collective negotiations. The purpose of the remand was to clarify the record as to which employee organization asserts representational rights pursuant to the New York Charter Schools Act of 1998, Education Law §2854(3)(b-1).

The Board’s decision provides an important practice tip for practitioners before PERB. In remanding the case, the Board emphasized the value and importance of stipulated records as an economical and convenient means of presenting relevant evidence in support of claims and defenses before an ALJ. At the same time, the Board reminded the parties that they retain the same level of responsibility and care for ensuring a complete record through a stipulated record or through the presentation of evidence at a hearing before an ALJ. (U-27727, 12/18/09)

BOARD OF EDUCATION OF THE CITY SCHOOL DISTRICT OF THE CITY OF NEW YORK. The Board granted a motion seeking an extension of time to file exceptions pursuant to §213.4 of PERB’s Rules of Procedure. Based upon the unique facts and circumstances set forth in the affidavits submitted by the employer in support of its motion, the Board concluded that the employer demonstrated extraordinary circumstances warranting the grant of additional time to file exceptions. The employer’s affidavits established that a breakdown in its established administrative procedure for the internal distribution of decisions resulted in a delay in the employer’s attorneys learning of the ALJ’s decision. In granting the motion, the Board emphasized that the delay was not the result of any form of neglect, omission or delays by the District’s attorneys. Finally, the Board reaffirmed the high standard that must be met to demonstrate extraordinary circumstances under §213.4 of the Rules. (U-28706, 12/18/09)

UNITED FEDERATION OF TEACHERS, LOCAL 2, AFT, AFL-CIO (GOLDSTEIN). The Board denied exceptions challenging a decision by an ALJ granting an unopposed motion by an employee organization seeking dismissal of an improper practice charge based upon the charging party’s failure to respond to the ALJ’s directive that he file an affidavit explaining his absence at the scheduled hearing. The Board held that the charging party’s failure to respond to the ALJ’s directive and his failure to respond to the employee organization’s motion demonstrated a clear and calculated decision to disregard prescribed procedures for pursuing his charge so as to constitute an abandonment of his claim. (U-28828, 12/18/09)

NEW YORK STATE CORRECTIONAL OFFICERS AND POLICE BENEVOLENT ASSOCIATION, INC. (HUNTER). The Board denied a motion by a charging party seeking an extension of time to file exceptions pursuant to §213.4 of PERB’s Rules of Procedure (Rules). The Board concluded that the charging party had failed to set forth sufficient and relevant facts demonstrating extraordinary circumstances. In support of her motion, the charging party asserted that she had misread the notice accompanying the ALJ’s decision and erroneously believed that she had 30 days to file exceptions. The Board found that the grounds set forth in the charging party’s motion were insufficient to meet the high standard necessary to demonstrate extraordinary circumstances under §213.4 of the Rules. (U-28615, 12/18/09)

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Declaratory Rulings

NO RECENT BOARD DECLARATORY RULINGS.

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Strikes

NO RECENT STRIKE BOARD DECISIONS.

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Local Procedures

NO RECENT LOCAL PROCEDURES DECISIONS.

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Other Matters

NO RECENT OTHER MATTERS DECISIONS.

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Decisions of the Office of Public Employment Practices and Representation

Representation

SOUTHWESTERN NURSES ASSOCIATION AND SOUTHWESTERN CENTRAL SCHOOL DISTRICT AND CIVIL SERVICE EMPLOYEES ASSOCIATION, INC., LOCAL 1000, AFSCME, AFL-CIO. The decertification portion of a certification/decertification petition was granted, removing the title of registered professional nurse from a unit of noninstructional school employees, where the registered professional nurse was the only professional title in the unit and the qualifications and duties of the position, as compared to the remaining unit titles, created a conflict of interest sufficient to remove the title. The petition to create a unit of three nurses was dismissed, and the title was placed in the bargaining unit of teachers and other professional employees represented by the Southwestern Teachers Association, which filed a letter agreeing to represent the title. (ALJ Fitzgerald, C-5869, 9/21/09)

SOUTHAMPTON TOWN SUPERIORS OFFICERS ASSOCIATION, INC. AND TOWN OF SOUTHAMPTON AND PATROLMAN’S BENEVOLENT ASSOCIATION OF SOUTHAMPTON TOWN, INC. Fragmentation of supervisors from a unit with police officers was appropriate where evidence indicated not only the potential for conflict based on supervisory duties, but recurrent actual conflicts arising out of differing interests and the exercise of authority. The petition for certification/decertification was duly filed by an “employee organization” under the Act based on the group’s demonstrating that it has the various indicia of that status and in accordance with PERB’s broad construction of the applicable criteria. (ALJ Cacavas, C-5805, 10/1/09)

LONG BEACH SCHOOL EMPLOYEES ASSOCIATION AND BOARD OF EDUCATION OF THE LONG BEACH CITY SCHOOL DISTRICT. The Association filed a unit clarification and/or placement petition seeking a finding that the position of Joyce Hanechak, District Treasurer, is in or should be placed in the bargaining unit it represents. The ALJ dismissed the clarification petition, since the position is not mentioned in the contractual recognition agreement and no evidence was presented that the position was already included in the unit. The ALJ granted placement with respect to Hanechak’s position finding that the position has a community of interest with the unit positions and does not qualify to be designed as confidential pursuant to §201.7(a) of the Act. (ALJ Blassman, CP-1132, 10/7/09)

HYDE PARK TEACHERS ASSOCIATION AND HYDE PARK CENTRAL SCHOOL DISTRICT. Pursuant to a unit placement petition filed by the Hyde Park Teachers Association, the unrepresented titles of registered nurse and occupational therapist were placed in a bargaining unit comprised of teachers rather than a bargaining unit comprised of teaching assistants, secretarial and clerical personnel, monitors and teacher aides, represented by the Hyde Park United Employees Association. The Board’s decision in Ichabod Crane Central School District, 33 PERB ¶3042 (2000) was dispositive, and also, the Association’s unit was determined to be the most appropriate unit placement based on shared mission and professional community of interest. (ALJ Wlasuk, CP-1152, 10/15/09)

DISTRICT COUNCIL 37, AFSCME, AFL-CIO AND BOARD OF EDUCATION OF THE CITY SCHOOL DISTRICT OF THE CITY OF NEW YORK AND LOCAL 237, INTERNATIONAL BROTHERHOOD OF TEAMSTERS. The ALJ granted DC 37’s unit placement petition that sought, pursuant to §201.7(a) of the Act, to include the newly created titles of customer information representative (CIR) levels I, II and III, in the bargaining unit it represents. The ALJ found that a closer community of interest exists between the CIRs and the employees in DC 37’s unit than with the employees in Local 237’s unit. The ALJ noted that the CIRs respond to inquiries from employees and other persons, as do the clerical employees and benefits examiners who are in DC 37’s unit. The ALJ further noted that the CIR IIs process benefit and leave applications, which is similar to the work performed by benefit examiners. Also found to be important was the fact that some CIR IIs previously performed their current job functions when they worked in positions that are in DC 37’s unit prior to the creation of the CIR titles. Regarding Local 237’s unit, the ALJ noted that the only position with duties similar to the CIRs primarily worked as the assistant editor for a quarterly retirement benefits newsletter and, therefore, has less of a community of interest with the CIRs. (ALJ Blassman, CP-1115, 11/2/09)

CIVIL SERVICE EMPLOYEES ASSOCIATION, INC., LOCAL 1000, AFSCME, AFL-CIO AND GROTON CENTRAL SCHOOL DISTRICT. The Association filed a unit clarification/unit placement petition seeking a finding that the three positions of secretary to the principal (High School, Middle School and Elementary School) are either in the bargaining unit it represents, or should be placed there. The ALJ dismissed the unit clarification petition because the contract’s recognition clause explicitly excluded the at-issue positions. However, the ALJ granted the unit placement based on the shared community of interest with the unit positions, and specifically, the fact that the Association currently represents one other secretary to the principal position. (ALJ Wlasuk, CP-1129, 12/3/09)

COUNTY OF NASSAU AND NASSAU COMMUNITY COLLEGE AND ADJUNCT FACULTY ASSOCIATION AT NASSAU COMMUNITY COLLEGE AND NASSAU COMMUNITY COLLEGE FEDERATION OF TEACHERS. The ALJ dismissed the AFA’s clarification petition, which sought a determination that the position of LINCC lecturer (lecturers teaching a series of ESL language immersion courses known “LINCC”) was already encompassed within its unit. The ALJ dismissed the clarification petition on the ground that the contractual recognition clause was too generalized upon which to base clarification and the positions listed elsewhere in the agreement did not include that of lecturer. Proof of a community of interest, without more, was found to be insufficient to support clarification. The ALJ granted the County’s placement petition which sought, as amended, to place the position of LINCC lecturer in the unit represented by the NCCFT. The ALJ held that, although the LINCC lecturers were different from the full-time faculty represented by the NCCFT because they are not eligible for tenure and do not participate in the governing structure of the College, they nonetheless held a closer community of interest with the NCCFT faculty than the adjunct faculty represented by the AFA. The closer community of interest was based upon the fact that the LINCC lecturers and the NCCFT represented employees both work full-time, receive health insurance and other fringe benefits, are given an office and are required to hold office hours, counsel students and participate in the College’s professional life by attending faculty meetings and serving on committees. The adjunct faculty in AFA’s unit, in contrast, are part-time employees who receive no health insurance or other fringe benefits, are not given an office and do not maintain office hours or serve on committees and, therefore, have less of a connection to the College. (ALJ Blassman, CP-1123 & CP-1140, 12/17/09)

PENFIELD ASSOCIATION OF EDUCATIONAL OFFICE PERSONNEL AND PENFIELD CENTRAL SCHOOL DISTRICT. Pursuant to a unit placement petition, the newly created titles of computer services liaison, network technician and senior network technician at the Penfield Central School District were added to a unit represented by the Penfield Association of Educational Office Personnel (Association), a unit which included related technical titles. The unit clarification aspect of the petition was dismissed, as the unit definition was title specific and the newly created titles were not listed. The District’s assertion that the titles are more appropriately placed in the bargaining unit represented by the Penfield Administrative Council was rejected, due to a lack of community of interest with the administrative titles. (ALJ Fitzgerald, CP-1185 (12/24/09)

PATROLMAN’S BENEVOLENT ASSOCIATION OF SOUTHAMPTON TOWN, INC. AND TOWN OF SOUTHAMPTON. The ALJ dismissed the PBA’s unit clarification and/or unit placement petition which sought a determination that the position of “police officer part-time/seasonal” (PSPO) is or should be placed in the negotiating unit it represents. The ALJ dismissed the unit clarification portion of the petition on the ground that the agreement’s recognition clause, which is title specific, did not indicate that the position was in the unit. The ALJ rejected the PBA’s argument that the unit title of “police officer” included full-time, part-time and seasonal police officers, since the Civil Service Department treated the titles as different positions and the agreement was, at best, vague regarding that issue because it did not specify whether only full-time or less than full-time employees were included in the unit. The ALJ noted that none of the other terms of the agreement or the manner in which the PBA treated the PSPOs over the years supported a finding that they were already included in the PBA’s unit. As to unit placement, the ALJ found that, despite the existence of a strong community of interest based upon shared police duties, placement must be denied because a conflict of interest arose due to the fact that unit police officers supervised, issued evaluations for and disciplined the PSPOs. (ALJ Blassman, CP-1168, 1/27/10)

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Management / Confidential

WASHINGTONVILLE CENTRAL SCHOOL DISTRICT. The District’s application to designate an account clerk as confidential was granted where the parties consented to the designation and the factual averments in the application supported such designation. (ALJ Wlasuk, E-2477, 12/4/09)

COUNTY OF ST. LAWRENCE. The District’s application to designate a micro-computer operator as confidential was granted where the parties consented to the designation and the factual averments in the application supported such designation. (ALJ Wlasuk, E-2488, 12/15/09)

PATCHOGUE-MEDFORD UNION FREE SCHOOL DISTRICT. Where a clerk typist assists and acts in a confidential capacity to a managerial employee, a confidential designation is warranted. (ALJ Cacavas, E-2495, 12/15/09)

JAMESTOWN URBAN RENEWAL AGENCY. JURA’s application to designate the financial coordinator as confidential pursuant to §201.7(a) of the Act was granted where it was found that he was exposed to confidential bargaining information and had a confidential relationship to the executive secretary for JURA, a managerial employee. (ALJ Doerr, E-2464, 1/29/10)

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Improper Practices

LORI A. CALBERT AND BOARD OF EDUCATION OF THE CITY SCHOOL DISTRICT OF THE CITY OF NEW YORK. The Director dismissed a charge alleging that the employer violated the Act because there are no facts to arguably establish a violation within four months of the filing of the charge and because individuals lack standing to allege breaches of §209-a.2(b) of the Act. (Director Klein, U-29336, 9/3/09)

WILLIE JOHNSON, JR. AND CAPITAL DISTRICT TRANSPORTATION AUTHORITY. The Director dismissed a charge alleging that the employer violated §§209-a.2(a), (b) and (c) of the Act because an employer cannot violate those subsections of the Act, an individual lacks standing to allege breaches of §209-a.2(b), and the charge was not sworn as required by §204.1(a)(1) of the Rules. (Director Klein, U-29381, 9/11/09)

OLEAN PROFESSIONAL FIREFIGHTERS ASSOCIATION, LOCAL 1796, IAFF, AFL-CIO AND CITY OF OLEAN. The charge alleging that the City violated the Act when it hired parttime firefighters, was deferred to the parties’ grievance procedure as the Association filed two grievances complaining of the same acts as set forth in the charge. (ALJ Doerr, U-29280, 9/14/09)

PROFESSIONAL STAFF CONGRESS/CUNY AND CITY UNIVERSITY OF NEW YORK. The ALJ dismissed a charge alleging that CUNY demoted and reduced the salary of two employees because of their protected activity. The ALJ found that the initial protected activity occurred after the first adverse employment action, and that the charging party failed to show a causal connection between the adverse actions and the protected activity. Additionally, CUNY had a legitimate business reasons for its actions. (ALJ Maier, U-28874, 9/14/09)

VICTOR C. BUCHALSKI AND UNITED STEELWORKERS, LOCAL 9434-00 AND CITY OF NIAGARA FALLS. An improper practice charge filed by Victor C. Buchalski alleging that the United Steelworkers, Local 9434-00 (Steelworkers) violated §209-a.2(c) of the Public Employees’ Fair Employment Act when it failed to challenge the termination of health insurance benefits following his disability retirement was dismissed, as the charge was untimely filed more than four months after he had been advised by the union that it would not pursue his claim. Buchalski’s assertion that his time to file ran from the date he received a copy of the Steelworkers’ counsel’s letter regarding the merits of his claim was rejected. Moreover, the charge would have been dismissed on the merits since there was no showing that the decision was arbitrary, discriminatory or in bad faith. (ALJ Fitzgerald, U-28360, 9/21/09)

CIVIL SERVICE EMPLOYEES ASSOCIATION, INC., LOCAL 1000, AFSCME, AFL-CIO AND COUNTY OF ALBANY. The ALJ conditionally dismissed and deferred to the contractually negotiated grievance procedure a charge alleging a violation of §209-a.1(d) of the Act based on the employer’s unilateral implementation of a plan to furlough county employees one day per month for five months. (ALJ Burritt, U-29315, 9/22/09)

LOCAL 517S PRODUCTION AND SALES DISTRICT COUNCIL, U.F.C.W. AND SUFFOLK COUNTY REGIONAL OFF-TRACK BETTING CORPORATION. Local 517S’ charge, alleging that the Suffolk County Regional OTB violated §209-a.1(a) and (d) of the Act when it announced that, beginning June 19, 2009, unit employees would have to pay fifteen percent of the cost of their health insurance premiums, was jurisdictionally deferred to a pending grievance upon the parties’ consent. (ALJ Blassman, U-29162, 9/23/09)

MICHAEL GOLDSTEIN AND THE UNITED FEDERATION OF TEACHERS AND BOARD OF EDUCATION OF THE CITY SCHOOL DISTRICT OF THE CITY OF NEW YORK. Where a charging party disagreed with the denial of his request to participate in a hearing by telephone, and both failed to attend the proceeding and to contact the administrative law judge before or after to explain his actions and intentions regarding his claim, the case was dismissed. (ALJ Cacavas, U-28828, 9/24/09)

PATRICIA MONTANINO AND TOWN OF ISLIP. The Director dismissed a charge alleging that the employer violated the Act because it does not identify any subsection of the Act allegedly violated as required by §204.1(b)(3) of the Rules of Procedure and the date of the alleged improper practice was not identified as required by §204.1(b)(3) of the Rules. (Director Klein, U-29426, 9/25/09)

LOCAL 891, INTERNATIONAL UNION OF OPERATING ENGINEERS, AFL-CIO AND BOARD OF EDUCATION OF THE CITY SCHOOL DISTRICT OF THE CITY OF NEW YORK. An ALJ held that the District violated the Act when it unilaterally terminated that past practice of giving parking permits to unit employees upon request. The practice of free parking had existed for a sufficient period of time to give rise to the expectation that it would continue. The ALJ rejected that District’s defense that the granting of the permits was not a term and condition of employment because it only granted the chance, not the guarantee, of free parking. (ALJ Maier, U-28706, 9/25/09)

LOCAL 891, INTERNATIONAL UNION OF OPERATING ENGINEERS, AFL-CIO AND BOARD OF EDUCATION OF THE CITY SCHOOL DISTRICT OF THE CITY OF NEW YORK. The ALJ dismissed Local 891’s charge, which alleged that the District violated §§209-a.1(a) and (d) of the Act when it assigned to custodian engineers pest control duties that were not inherently part of their work and that significantly increased their workload. The ALJ found that the custodian engineers already performed much of those duties and that, to the extent that new duties were added, they were inherent to the work of custodian engineers. The ALJ further found that the record failed to support the allegation that the custodian engineers were required to perform significantly more work in the same amount of time. The ALJ dismissed the allegation, raised in Local 891’s post-hearing brief, that the pest control duties decreased custodian engineers’ compensation, because Local 891 did not raise that allegation at the commencement of the hearing when the ALJ clarified the extent of the charge. (ALJ Blassman, U-27468, 9/30/09)

BOARD OF EDUCATION OF THE CITY SCHOOL DISTRICT OF THE CITY OF NEW YORK AND PLUMBERS LOCAL UNION NO. 1, U.A., AFL-CIO. The ALJ issued a decision reaffirming a prior finding that the District violated the Act by failing to provide information pursuant to request regarding the transfer of unit work. This Board remanded the matter due to an inconsistency in a prior Board decision, necessitating the issuance of another decision. (ALJ Maier, U-25883, 10/1/09)

ROCKVILLE CENTRE VILLAGE EMPLOYEES CIVIL SERVICE ASSOCIATION, INC. AND VILLAGE OF ROCKVILLE CENTRE. An ALJ held that the Village violated the Act when it transferred the exclusive unit work of parking meter coin collection work to a nonunit employee. The Village’s defenses that it had the management right to determine the time span within which work should be performed, that the Association did not make a demand to bargain and to find a violation would be against public policy were rejected. (ALJ Maier, U-28846, 10/1/09)

SUFFOLK COUNTY ASSOCIATION OF MUNICIPAL EMPLOYEES, INC. AND COUNTY OF SUFFOLK. SCAME’s charge, alleging that the County violated §§209-a.1 (a) and (d) of the Act when it unilaterally transferred the exclusive unit work of arrest processing, was jurisdictionally deferred upon the parties’ consent to a pending grievance. (ALJ Blassman, U-28592, 10/5/09)

MICHAEL ABRAHAMS AND CIVIL SERVICE EMPLOYEES ASSOCIATION, LOCAL 1000, AFSCME, AFL-CIO AND VILLAGE OF HEMPSTEAD. The ALJ dismissed Abrahams’ charge, which alleged that CSEA had violated §209-a.2 (a) and (c) of the Act when it refused Abrahams’ request to represent him in a grievance challenging his termination as village administrator. The ALJ found that Abrahams’ position was not in the unit and that CSEA, therefore, did not owe Abrahams any representational duty under the Act. (ALJ Blassman, U-28292, 10/6/09)

ARDSLEY POLICEMEN’S BENEVOLENT ASSOCIATION AND VILLAGE OF ARDSLEY. The ALJ sustained the PBA’s charge that the Village violated §209-a.1(d) of the Act when the chief of police unilaterally prohibited unit employees from performing any off duty police work for other employers. The ALJ rejected the Village’s argument that no change had occurred because the chief’s prohibition was consistent with the Department’s pre-existing rules and regulations. The record evidence demonstrated that, before the police chief’s announced prohibition, unit employees had been permitted to perform such work with the police chief’s authorization. The chief’s announced prohibition further restricted unit employees’ ability to earn money by performing off duty police work by imposing a total prohibition upon such employment. (ALJ Blassman, U-25524, 10/8/09)

ELLICOTTVILLE TEACHERS ASSOCIATION AND ELLICOTTVILLE CENTRAL SCHOOL DISTRICT. An improper practice charge alleging a violation of the duty to negotiate a change in practice, whereby teachers had received early release on the workday prior to the December recess, was dismissed. The District was found to have satisfied its duty to negotiate the matter as a result of the terms of the parties’ agreement which defined both the work year and the workday of teachers, thus, it was privileged to revert to the terms of that agreement despite its prior practice. (ALJ Fitzgerald, U-28394, 10/20/09)

CHRISTINE V. SERAFIN, AMERICAN FEDERATION OF STATE, COUNTY AND MUNICIPAL EMPLOYEES, LOCAL 650, AFL-CIO AND CITY OF BUFFALO. Serafin’s charge alleging that AFSCME Local 650 violated its duty of fair representation was dismissed following submission of an offer of proof. Serafin failed to plead or present facts to establish that Local 650’s refusal to file an overtime grievance on her behalf was arbitrary, discriminatory or in bad faith. Serafin was told and understood that an earlier and identical grievance was withdrawn by Local 650 at Step 2 on a finding that Serafin did not qualify for the overtime opportunities available. Further, broad and conclusory allegations that Local 650 discriminated in the assignment of overtime, granting opportunities to a favored few, without supporting facts cannot form the basis for finding a violation under the Act. Neither does a disagreement as to the merits of a grievance establish arbitrary, discriminatory or bad faith conduct. Finally, a union is under no statutory obligation to reiterate its refusal to file a grievance in a form demanded by the charging party. (ALJ Poland, U-28299, 10/20/09)

POLICE ASSOCIATION OF NEW ROCHELLE AND CITY OF NEW ROCHELLE AND NEW ROCHELLE SUPERIOR OFFICERS’ ASSOCIATION. The ALJ sustained the charge, finding that the City violated §209-a.1(d) of the Act when it transferred to nonunit supervisors special-duty detail work that had been previously performed exclusively by Association unit employees. The ALJ rejected the City’s and SOA’s argument that the Association unit employees did not have exclusivity over the work because it required only the performance of generalized police functions, such as patrolling, providing a police presence and traffic control work, which superior officers are also qualified to perform. The ALJ noted that the Association need not prove that its unit employees were the only ones qualified to perform the in-issue work, but only that they had performed it exclusively. The ALJ also rejected the argument that exclusivity was breached when superior officers performed special-duty details, since the superior officers did not perform the same duties as Association unit employees, but performed supervisory work. The ALJ also found without merit the City’s argument exclusivity was breached when private vendors hired civilians to perform traffic control at construction and excavation sites, since there was no evidence that the City had required the work to be performed or that the work was performed by or on behalf of City. (ALJ Blassman, U-26722, 10/21/09)

TOWN OF FISHKILL POLICE FRATERNITY, INC. AND TOWN OF FISHKILL. The charge alleged a wide-ranging campaign of harassment, retaliation and interference in violation of §§209-a.1(a) (b) and (c) of the Act, and of related unilateral changes in terms and conditions of employment and failure to continue the terms of an expired agreement in violation of §§ 209-a.1(d) and (e) of the Act. The ALJ found a violation of subsection (d) when the Town unilaterally placed restrictions on the PBA’s use of its e-mail system. The ALJ also found violations of subsections (a) and (c) of the Act in counseling an employee for the protected activity of discussing the contract impasse and in evaluating that employee based on that activity and on an issue that had already been resolved. The charge was in all other respects dismissed. (ALJ Burritt, U-27331 & U-27568, 10/21/09)

ODESSA HUNTER, NEW YORK STATE CORRECTIONAL OFFICERS AND POLICE BENEVOLENT ASSOCIATION, INC., AND STATE OF NEW YORK (DEPARTMENT OF CORRECTIONAL SERVICES). The charge that the exclusive bargaining representative breached its duty of fair representation by failing to notify charging party of its decision to close her grievance and when it conspired with her employer to withhold information from her following her termination was dismissed following charging party’s submission of an offer of proof. The charging party failed to set forth specific, timely and relevant facts in support of her charge. That the union’s decision to close her grievance failed to reach her was due to her failure to notify it of her change of address. Her remaining allegations were untimely and conclusory and could not form the basis for a finding of a violation of the Act. (ALJ Poland, U-28615, 10/26/09)

PLATTSBURGH PERMANENT FIREMEN’S ASSOCIATION, LOCAL 2421, IAFF AND CITY OF PLATTSBURGH. An ALJ conditionally dismissed a charge alleging that the City of Plattsburgh violated the Act when it unilaterally changed a practice concerning disability retirement applications, deferring to the parties’ contractual grievance procedures. (ALJ Carlson, U-29216, 10/26/09)

NEW YORK STATE PUBLIC EMPLOYEES FEDERATION, AFL-CIO AND COUNTY OF ALBANY. An ALJ conditionally dismissed a charge alleging that the County of Albany violated the Act when it unilaterally implemented a plan to furlough County employees one day per month over a five month period, deferring to the parties’ contractual grievance procedures. (ALJ Burritt, U-29396, 10/27/09)

CIVIL SERVICE EMPLOYEES ASSOCIATION, INC., LOCAL 1000, AFSCME, AFL-CIO AND STATE OF NEW YORK (RACING & WAGERING BOARD). An ALJ conditionally dismissed a charge alleging that the State of New York Racing & Wagering Board violated the Act when it unilaterally altered a practice of allowing per diem bargaining unit members assigned to the Aqueduct race track to charge absences from work to accrued leave on dates when races at Aqueduct were cancelled. (ALJ Carlson, U-29107, 11/6/09)

TOWN OF WALLKILL POLICE BENEVOLENT ASSOCIATION, INC. AND TOWN OF WALLKILL. In connection with bad faith bargaining charges filed by the PBA against the Town and by the Town against the PBA, the ALJ dismissed the Town’s claim that the PBA’s refusal to withdraw, prior to a declaration of impasse, its proposal on discipline constituted a violation of §209-a.2 (b) of the Act. The ALJ sustained the PBA’s charge against the Town, finding that the Town failed to negotiate in good faith when it conditioned further negotiations on the PBA’s withdrawal of its proposal on police discipline. As the parties later resumed negotiations, the remedy was limited to an order that the Town sign and post a notice of the violation. (ALJ Burritt, U-28331 & U-28379, 11/9/09)

MICHAEL A. DAVITT AND CIVIL SERVICE EMPLOYEES ASSOCIATION, INC., LOCAL 1000, AFSCME, AFL-CIO AND COUNTY OF ROCKLAND. The Director dismissed a charge alleging that both the union and employer violated the Act because it does not arguably establish a violation of any of the subsections of §209-a of the Act. (Director Klein, U-29420, 11/16/09)

NEW YORK STATE LAW ENFORCEMENT OFFICERS UNION, COUNCIL 82, AFSCME, AFL-CIO, LOCAL 2796 and STATE OF NEW YORK (OFFICE OF PARKS, RECREATION AND HISTORIC PRESERVATION). An ALJ dismissed a charge alleging that the State of New York Office of Parks, Recreation and Historic Preservation violated the Act by unilaterally altering a past practice under which officer recruits had worked five eight-hour workdays per week, for a total of 40 hours per week. The ALJ found that the charging party failed to prove the existence of an enforceable past practice. (ALJ Carlson, U-27324, 11/19/09)

CIVIL SERVICE EMPLOYEES ASSOCIATION, INC., LOCAL 1000, AFSCME, AFL-CIO, PUTNAM COUNTY UNIT #8150, PUTNAM COUNTY LOCAL 840 and MAHOPAC CENTRAL SCHOOL DISTRICT. An ALJ dismissed a charge alleging that the Mahopac Central School District violated §209-a.1(d) of the Act when it unilaterally changed an alleged past practice of hiring any member of the bargaining unit who expressed an interest to work in a summer program for seriously disabled students. The ALJ found that there was no change in the District’s practice when the District considered the qualifications of the applicants, and dismissed the charge. (ALJ Burritt, U-27924, 11/23/09)

ROBERT SETLOCK, JR. and STATE OF NEW YORK (DEPARTMENT OF CORRECTIONAL SERVICES – ALBION CORRECTIONAL FACILITY). Setlock’s improper practice charge alleging that DOCS violated §§ 209-a.1 (a) and (c) of the Act by terminating him for having filed a grievance was dismissed. Charging party failed to establish that Setlock’s supervisor, who authored his probationary period evaluation reports and recommended termination of his probationary employment, knew that he filed a grievance prior to his having filed the at-issue improper practice charge. Even Decisions of the Office of Representation (September ‘09 - January ‘10) 11 were it found that his supervisor knew of the grievance, the evaluation reports and various memorandum and counseling letters establish more than legitimate reasons for terminating his employment. (ALJ Doerr, U-27139, 12/3/09)

GERALD J. O'CONNOR AND FACULTY ASSOCIATION OF SUFFOLK COUNTY COMMUNITY COLLEGE AND SUFFOLK COUNTY COMMUNITY COLLEGE. The Director dismissed a charge alleging that the union breached its duty of fair representation because the operative act occurred more than four months prior to the filing of the charge. The alleged violation of §209-a.2(b) of the Act is also dismissed because individual employees lack standing to allege a violation of that subdivision. (Director Klein, U-29482, 12/4/09)

AMERICAN FEDERATION OF STATE, COUNTY AND MUNICIPAL EMPLOYEES, LOCAL 264 AND BUFFALO MUNICIPAL HOUSING AUTHORITY. The Buffalo Municipal Housing Authority did not violate its bargaining obligation when it unilaterally changed the Assistant Superintendent of Maintenance job specification to include a description of duties performed by employees in the title. The ALJ noted that there was no evidence to support claims that the responsibilities of the position were significantly expanded. Evidence showed that although the content added to the job specification could be interpreted as expanding the responsibilities of the title, no new duties or responsibilities were in fact added. The ALJ concluded that a possibility that the new job description could be interpreted as expanding duties is, without an actual new duty assignment, insufficient to support a finding that the essential character of the position has been altered or that new duties outside the inherent nature of the position have been added. (ALJ Poland, U-28065,12/15/09)

UNIFORMED PATROLMEN’S ASSOCIATION OF THE GREECE POLICE DEPARTMENT AND TOWN OF GREECE. The charge was deferred to the parties’ grievance and arbitration procedure under their current collectively negotiated agreement. The charge alleged a violation of §209-a.1(d) of the Act when the Town subcontracted the exclusive work of the community services position to an employee outside the unit. The Association filed a grievance based upon the same or similar facts as pled in the charge. Accordingly, the charge was deferred pursuant to the Board’s decision in Herkimer County BOCES. (ALJ Doerr, U-29511, 12/17/09)

YONKERS FEDERATION OF TEACHERS, LOCAL 860, AFT, AFL-CIO AND YONKERS CITY SCHOOL DISTRICT. An ALJ conditionally dismissed and deferred to the contractual grievance procedure a charge alleging that the Yonkers City School District violated the Act when it unilaterally determined that YFT members would be charged a “participant fee” to continue their participation in the District’s previously cost free Internal Revenue Code §403-b program. (ALJ Burritt, U-28934, 12/17/09)

ADRIENNE FLOYD AND DISTRICT COUNCIL 37, AFSCME, AFL-CIO, LOCAL 372 AND BOARD OF EDUCATION OF THE CITY SCHOOL DISTRICT OF THE CITY OF NEW YORK. Upon the respondents’ motion, the ALJ dismissed a charge alleging that DC37 had violated §209-a.2(a) and (c) of the Act when it failed to properly represent Floyd during a disciplinary grievance hearing. The charge was found to be untimely, since it alleged that DC 37 had acted improperly during an October 29, 2008 hearing and the charge was filed on May 14, 2009, beyond the required four-month filing period. (ALJ Blassman, U-29158, 12/21/09)

ROCHESTER TEACHERS ASSOCIATION AND ROCHESTER CITY SCHOOL DISTRICT. Improper practice charge filed by the Rochester Teachers Association alleging a violation of the Act by virtue of the District’s elimination of unit employees’ role in interviewing and hiring lead teachers was conditionally dismissed subject to a determination in the grievance arbitration pending on the same matter. (ALJ Fitzgerald, U-29251, 12/22/09)

RIVERHEAD CENTRAL SCHOOL DISTRICT. An ALJ dismissed a charge alleging that the District bargained in bad faith when it raised a new demand as a condition to executing an agreement. The ALJ found that the parties had not in fact reached an agreement and, in any event, the purportedly new demand was not in fact a new proposal. (ALJ Maier, U-29080, 1/14/10)

COUNTY OF ULSTER AND CIVIL SERVICE EMPLOYEES ASSOCIATION, INC., LOCAL 1000, AFSCME, AFL-CIO. The charge alleged that the County of Ulster violated §209-a.1(d) of the Act. The ALJ found a violation of subsection (d) when the County refused to provide CSEA with interview questions, notes and rankings from the interviews of candidates for the Senior Public Health Sanitarian position in 2006 and when it failed to provide CSEA with the specific criteria used in evaluating candidates for said position. (ALJ Carlson, U-27550, 1/27/10)

PUBLIC EMPLOYEES FEDERATION AND STATE OF NEW YORK (RACING AND WAGERING BOARD). A unilateral 25 percent reduction in per diem rates of pay for seasonal unit employees at the State’s horse racing tracks violated §209-a.1(d) of the Act. Defenses based upon the State Finance Law and the standard for an enforceable past practice were among those which were unsuccessful. (Assistant Director Comenzo, U-17811, 1/28/10)

ANGELA FAIL-MAYNARD AND LONG BEACH CITY SCHOOL DISTRICT AND LONG BEACH ADMINISTRATORS’ UNION. The Director dismissed the charge, as amended, against the District because public employers cannot violate §209-a.2(a) of the Act. The Director also dismissed the amended charge alleging that the Union breached its duty of fair representation because there were no facts to arguably establish the Union’s conduct as arbitrary, discriminatory or in bad faith. (Director Klein, U-29565, 1/29/10)

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