County of Chautauqua v. Civil Service Employees Ass’n, 8 N.Y.3d 513 (2007)
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A collective bargaining agreement (CBA) provision that conflicts with the essential public policy embodied in Civil Service Law § 80 regarding layoffs in the civil service is not subject to arbitration.
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Summary
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The County of Chautauqua sought a stay of arbitration regarding grievances filed by the Civil Service Employees Association (CSEA) concerning layoffs and displacement rights under their collective bargaining agreement (CBA). The County argued that the CBA conflicted with Civil Service Law § 80. The Court of Appeals held that the CBA provision mandating layoffs based solely on seniority conflicted with the public policy embodied in Civil Service Law § 80, which requires consideration of job titles and positions. Therefore, this issue was not arbitrable. However, the Court found that the CBA’s provision regarding interdepartmental displacement rights was arbitrable, as no explicit law or public policy prohibited such agreements.
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Facts
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Due to economic necessity, Chautauqua County decided to lay off employees. A conflict arose between the CBA’s section 14.05, which stipulated that layoffs be determined solely by seniority, and Civil Service Law § 80, which dictates layoffs based on seniority within specific job titles or positions. The County sought guidance from the Department of Civil Service, which advised that a CBA could not override the layoff units prescribed by section 80(4). The County proceeded with layoffs, and CSEA grieved, alleging violations of section 14.05 of the CBA, specifically regarding seniority-based layoffs and interdepartmental displacement rights.
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Procedural History
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The County initiated a CPLR article 75 proceeding seeking a permanent stay of arbitration, arguing that the CBA provisions conflicted with Civil Service Law § 80. Supreme Court partially granted the County’s petition, staying arbitration for competitive class employees but allowing it for noncompetitive/labor class employees. The Appellate Division reversed, compelling arbitration in its entirety. The Court of Appeals then modified the Appellate Division’s order, staying arbitration on the issue of seniority-based layoffs but allowing it on the issue of displacement rights.
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Issue(s)
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1. Whether a collective bargaining agreement provision mandating layoffs based solely on seniority, irrespective of job title or position, is arbitrable when it conflicts with Civil Service Law § 80, which requires consideration of job titles and positions in layoff decisions.
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2. Whether a collective bargaining agreement provision permitting interdepartmental employee displacement (