Patrolmen’s Benevolent Association v. City of New York, 41 N.Y.2d 205 (1976)
A statute suspending wage increases pursuant to collective bargaining agreements does not apply to wage increases mandated by a prior judicial judgment.
Summary
The Patrolmen’s Benevolent Association (PBA) sought to enforce a judgment requiring New York City to pay a 6% salary increase. The City argued that a subsequent state law freezing wages prohibited this payment. The Court of Appeals held that the wage freeze legislation, which suspended wage increases pursuant to collective bargaining agreements, did not apply to the PBA’s salary increase, as that increase was mandated by a judicial judgment predating the legislation. The Court reasoned that the statute’s language did not explicitly include judicial judgments and that the Legislature was aware of the judgment when enacting the wage freeze.
Facts
The PBA and New York City, unable to agree on a collective bargaining agreement, submitted their dispute to an impasse panel. The panel recommended an 8% salary increase for the first year and 6% for the second year. Both parties accepted the findings, and they were incorporated into a tentative agreement. The City refused to sign the agreement, citing financial difficulties. The PBA then sought to confirm the impasse panel’s award via a CPLR Article 75 proceeding. The City’s motion to dismiss was denied, and the petition was granted upon default on July 1, 1975. The City began paying the retroactive salary increase. In September 1975, the state enacted wage freeze legislation, and the City stopped paying the 1975-1976 increase.
Procedural History
The PBA moved to compel the City to comply with the July 1, 1975 judgment. The lower court found the wage freeze inapplicable but stayed enforcement of its judgment. Both parties appealed. The Appellate Division also found the wage freeze inapplicable to judgments and removed the stay. The Court of Appeals granted leave to appeal and certified the question of whether the Appellate Division’s order was properly made.
Issue(s)
Whether a state statute suspending wage increases pursuant to collective bargaining agreements or other analogous contracts applies to a wage increase mandated by a judicial judgment entered before the statute’s enactment.
Holding
No, because the statute’s language does not explicitly include judicial judgments, and the legislative history does not indicate an intent to encompass such judgments.
Court’s Reasoning
The Court emphasized that statutory interpretation should effectuate the Legislature’s intent, and clear, unambiguous language should be given its plain meaning. The statute suspended wage increases “pursuant to collective bargaining agreements or other analogous contracts.” The Court found that the wage increase in this case resulted from a judicially mandated remedy, not a collective bargaining agreement. There was no language suggesting a legislative intent to suspend judgments. The Court stated, “[A]n irrefutable inference must be drawn that what is omitted or not included was intended to be omitted or excluded.” The Legislature was aware of the July 1 judgment when enacting the wage freeze. Other statutes enacted at the same time specifically applied to judgments, demonstrating that the Legislature knew how to include judgments when it intended to do so. The Court also noted that a judgment entered upon the confirmation of an arbitral award has the same force and effect as a judgment in an action. Finally, the Court agreed with the Appellate Division that the lower court lacked the power to stay enforcement of its order. The Court found no merit in the City’s other arguments.