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Employment & Labor Law for Public Safety Agencies


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Arbitration Punishment Awards – Right of Courts to Interfere

• This section contains cases where courts have been asked either not to enforce or to set aside an arbitration award because reinstatement of an employee allegedly was contrary to public policy.

Other related topics: Arbitration Procedures, Disciplinary Punishment-In General and Impasse Arbitration.
     A police officer employed by a city was terminated after he committed an act of domestic battery and then lied about doing so. The union representing officers filed a grievance asserting that the discharge was not for just cause. An arbitrator agreed, and ordered that he be reinstated. A trial court found that the arbitration decision was void and in violation of public policy. An appeals court upheld that ruling. “We are aware of no case, and no statute, that requires an allegation of misconduct in this context be proved by clear and convincing evidence because the misconduct may also be criminal and because the City seeks to discharge the officer. There is well-defined and dominant public policy against acts of domestic violence. Acts of domestic violence are even more disturbing when committed by a police officer – whether on or off duty. It is a violation of public policy to require the continued employment of an officer who has been found to be abusive and untruthful. We find the standard of proof is preponderance of the evidence. The Arbitrator concluded the act was proved by a preponderance and the lie was proved by a preponderance. It would be repugnant to public policy to retain [him] as a police officer in these circumstances.” Decatur Police Benevolent and Protective Ass’n Labor Committee v. City of Decatur, #4-11-0764. 968 N.E.2d 749 (Ill. App. 2012).
     Upholding the termination of a police sergeant, a five-judge appellate panel wrote that "an arbitrator’s award should not be vacated for errors of law and fact committed by the arbitrator and the courts should not assume the role of overseers to mold the award to conform to their sense of justice. A court may vacate an arbitration award only if it violates a strong public policy, is irrational, or clearly exceeds a specifically enumerated limitation on the arbitrator's power." In this case, the arbitrator found that termination was the right penalty for the sergeant, who did not attempt to stop an allegedly intoxicated police detective from leaving a parking lot when he had reportedly been speeding, driving in an erratic manner, and hit a parked car. In re Arbitration Between Albany Police Supervisor's Assn. and the City of Albany, 95 A.D.3d 1491, 944 N.Y.S.2d 675, 2012 N.Y. App. Div. Lexis 3704, 2012 NY Slip Op 3704.
     Pennsylvania appellate court upholds an arbitration award that set aside a 17-day suspension of an off-duty state trooper, following his arrest in Maryland. Those charges were dropped. Penn. State Police v. State Troopers' Assn., 1821 C.D. 2009, 2010 Pa. Commw. Lexis 188.
     Appellate court affirms an arbitrator's decision to reinstate a mental health security aide who was fired for striking a patient. The employee's performance evaluations were positive, he had no prior problems of this nature despite having been assaulted numerous times in the past by patients. A disciplinary suspension plus a final warning was a rational outcome. Dept. of Central Mgmt. Services v. AFSCME, #5-08-0663, 2010 Ill. App. Lexis 554 (5th Dist.).
     Overturning an arbitrator, a deputy sheriff was lawfully removed during her probationary period and returned to her previous job as a dispatcher. The bargaining agreement precluded her from filing a grievance. Donini v. Frat. Order of Police, #08CA3251, 2009 Ohio 5810, 2009 Ohio App. Lexis 4889, 187 LRRM (BNA) 2572 (4th Dist.). Ohio appellate court concludes that an arbitrator was within his rights to conclude that a one-day suspension was arbitrable and the trial court correctly denied a motion by the sheriff's office to set aside the arbitration award. Marion Co. Sheriff's Office v. FOP Ohio Labor Council, #9-09-20, 2009 Ohio 6159, 2009 Ohio App. Lexis 5164 (3rd Dist.).
     Washington's Supreme Court concludes that in order to vacate an arbitrator's decision as contrary to public policy, "the public policy must be explicit, well defined, and dominant." The arbitrator had reinstated a deputy sheriff who was charged with 29 documented incidents of misconduct, including untruthfulness. Split by a 4-3 holding, the state's Supreme Court held that the arbitrator's decision did not violate an explicit, well defined, and dominant public policy. Kitsap Co Deputy Sheriff's Guild v. Kitsap Co., #80720-5, 2009 Wash. Lexis 979.
     Florida appellate court affirms an arbitration award that overturned the termination of a corrections employee. The award "was well within the submission to the arbitrator, violated no law or rule, and should be given effect." AFSCME C-79 v. Florida Dept. of Corrections, #1D08-162, 2009 Fla. App. Lexis 16874 (1st Dist.).
     Illinois appellate court sustains the termination of a corrections officer who, during a six-month period, had been progressively disciplined for calling in sick on 25 days without having accrued sick days. The three-judge panel overturned an arbitrator’s award, which had found that the discipline policy was unreasonable because its series of successively longer suspensions was punitive rather than remedial. The arbitrator’s powers were limited to reviewing only the validity of the Sheriff’s implementation of the sick leave policy. Cruz v. Cook County Sheriff’s Merit Bd., #1-08-2648, 2009 Ill. App. Lexis 797 (1st Dist.).
     In a 3-to-1 decision, a N.Y. appellate court sustains an arbitration award upholding the termination of a corrections officer for insubordination. She repeatedly ignored a sergeant’s directive to stop interrupting another employee. A defense that the charges were levied in retaliation for reporting a coworker for assaulting an inmate was rejected. Kowaleski and N.Y.S. Dept. Corr. Srvs., 505383, 2009 N.Y. App. Div. Lexis 2485 (3rd Dept.).
     Nebraska Supreme Court overturns an arbitration award that reinstated a state patrol officer who had joined the Knights Party, a Ku Klux Klan affiliated racist organization. "Nebraska public policy precludes an individual from being reinstated to serve as a sworn officer in a law enforcement agency if that individual’s service would severely undermine reasonable public perception that the agency is uniformly committed to the equal enforcement of the law and that each citizen of Nebraska can depend on law enforcement officers to enforce the law without regard to race." State v. Henderson, #S-07-010, 277 Neb. 240, 2009 Neb. Lexis 28.
     Appellate court concludes that an arbitrator improperly used a "just cause" analysis to set aside the grievant’s termination; the parties were bound by a last chance agreement "which limited the employee’s right to grieve/appeal." City of Yakima v. Yakima Police Assoc., #26799-7, 2009 Wash. App. Lexis 81.
    Federal appeals panel vacates a 342-day "time served" disciplinary suspension as arbitrary and capricious, because it was based solely on the length of time that elapsed between the date of the termination and the date of the arbitrator's decision. "There are many factors that a reviewing authority may and should take into account when determining the appropriate length of an employee's suspension. But it may not set the length of a suspension based solely on the time that it takes the reviewing authority to reach a decision. To permit the length of a suspension to be based solely on "time served" would make the penalty depend not on the Douglas factors, which reflect the individual employee's particular situation, but on the speed with which (1) the employee or his representative handled the case, and (2) the tribunal rendered its decision." Greenstreet v. Social Secur. Admin., #2007-3312, 2008 U.S. App. Lexis 20155 (Fed. Cir.).
     Pennsylvania appellate court overturns an arbitration award reinstating a worker who "repeatedly and egregiously sexually harassed" a coworker by engaging in behavior that was "lewd, lascivious and extraordinarily perverse." "If forced to honor the arbitration award, [management] will not be complying with Title VII ... which requires that an employer impose appropriate discipline for proven cases of sexual harassment in order to ensure a safe work environment free of sexual harassment." Phila. Housing Auth. v. AFSCME C-33, L-934, #2405 C.D. 2004, 2008 Pa. Comm. Lexis 417.
     Florida appellate panel reinstates an award where the arbitrator set aside termination as an inappropriate penalty. Although the CBA provided that an arbitrator could not mitigate a penalty, another section required a finding of just cause. Raynor v. Frat. Order of Police, #1D07-1439, 2008 Fla. App. Lexis 10829 (1st Dist.).
     Appellate court affirms an arbitration decision to change a termination to an eight-month suspension, for a firefighter that downloaded personnel data onto a personal computer at home. The conduct was isolated and not egregious, and the employer failed to prove that the reinstatement award was contrary to public policy. Brantley v. City of New Haven, #AC 27255, 100 Conn.App. 853, 920 A.2d 331, 2007 Conn. App. Lexis 194.
     Massachusetts appellate court declines to overturn an arbitrator's award that reduced the punishment of a corrections officer from termination to a six-month suspension, for opening a cell door for another officer who assaulted an inmate. The arbitrator found that the grievant "had no advance knowledge of what was going to transpire nor was he a party to it before or during the event." Sheriff of Suffolk Co. v. Jail Officers & Employees of Suffolk Co., #03-P-1154, 68 Mass. App. Ct. 903, 860 N.E.2d 963, 2007 Mass. App. Lexis 93.
     Ohio appellate court declines to set aside an arbitration award that reduced the punishment of a corrections officer that temporarily left his post. Cuyahoga County Sheriff's Dept. vs. Ohio P.B.A., #87620, 2006 Ohio App. Lexis 5735 (8th App. Dist. 2006). {N/R}
     Ohio appellate court reinstates an arbitrator's award, reducing a penalty from termination to a 40-hour suspension. After a suspect was Maced, he died while confined in an unventilated police car. The grievant failed to wash the suspect's face or keep him under observation. City of Cincinnati v. Queen City L-69 FOP (Caton), #C-050143,164 Ohio App.3d 408, 2005 Ohio 6225, 842 N.E.2d 588, 2005 Ohio App. Lexis 5601 (App. 1st Dist.); appeal denied, 2006 Ohio 1703, 2006 Ohio Lexis 873 (Ohio 2006). [2006 FP Sep]
     Ohio appellate court sustains an arbitrator's decision reinstating a police officer that was fired because of exercising poor judgment during a pursuit. The arbitrator's award was not unlawful, arbitrary or capricious. City of Lancaster v. FOP, #05 CA 103, 2006 Ohio 1380, 2006 Ohio App. Lexis 1252 (2006). {N/R}
     A divided appellate court affirms the termination of a police officer that lied under oath to help a fellow officer who killed an arrested man. In a 2-to-1 holding, the court set aside the arbitrator's award reducing the punishment to a three-day suspension because a penalty matrix used in deciding disciplinary punishment was not referenced in the bargaining agreement. City of Cincinnati v. Queen City Lodge (Spellen), #C- 040454, 2005 Ohio 1560, 2005 Ohio App. Lexis 1522, 177 LRRM (BNA) 2021 (2005); City of Cincinnati v. Queen City Lodge (Spellen), #A0509129 (Cm.Pl. Hamil. Co. 2006). {N/R}
     Ohio appellate court overturns an arbitration award that unconditionally required a public employer to reinstate a violent employee. Employers have a duty to prevent workplace violence, and an unconditional order of reinstatement, without anger management counseling and after-incident monitoring violates public policy. Akron Met. Housing Auth. v. L-2517 AFSCME, #22365, 161 Ohio App.3d 594, 2005 Ohio 2965, 831 N.E.2d 493, 2005 Ohio App. Lexis 2764 (9th Dist. 2005). [2005 FP Dec]
     Appellate court in Ohio overturns arbitrator's decision to reinstate a violent public employee. "Workplace safety is a well defined and dominant public policy based on federal, state, and common law."Akron Hous. Auth. v. Local 2517, AFSCME, #22365, 2005 Ohio 2965, 2005 Ohio App. Lexis 2764 (9th App. Dist. 2005). [2005 FP Sep]
     Appellate court reverses a trial judge that had set aside an arbitration award reinstating a police officer who committed a misdemeanor. City of Highland Park v. Teamster L-714, #2-04-0653, 2005 Ill. App. Lexis 396 (2nd Dist. 2005). [2005 FP Jul]
     Pennsylvania appellate court overturns an arbitration award and trial court decision that reinstated a laborer at an airport who falsified his time cards. The relevant consideration is not an analysis of the employee's job duties, but of the type of misconduct. Allegheny County Airport Auth. v. Construction Gen. Lab. Union L-1058, #1413 C.D. 2004, 2005 Pa. Commw. Lexis 201, 177 LRRM (BNA) 2053 (Pa. App. 2005).[2005 FP Jul]
     Ohio appellate court overturns an arbitration award where the punishment of an officer, who lied under oath, had been reduced from a termination to a three-day suspension. City of Cincinnati v. Queen City L-69, F.O.P., # C-040454, 2005 Ohio App. Lexis 1522, 2995 Ohio 1560 (1st Dist. 2005). [2005 FP Jun]
     Massachusetts Supreme Court overturns an arbitration award reinstating an officer that falsely arrested a citizen and repeatedly lied in his reports about the event. City of Boston v. Boston Police Assn., #SJC-09297, 443 Mass. 813, 824 N.E.2d 855, 2005 Mass. Lexis 151 (Mass. 2005). [2005 FP Jun]
     Massachusetts appellate court holds that an arbitrator's reinstatement of a Boston jail officer, that had failed to report an inmate assault by other officers and then gave IA investigators a false statement, will not be set aside by the courts. Reduction of the penalty to a six-month suspension without pay did not violate public policy. Sheriff of Suffolk County v. AFSCME C-93, #03-P-1154, 62 Mass. App. 915, 817 N.E.2d 336, 2004 Mass. App Lexis 1271 (2004). {N/R}
     Federal appeals court sustains an arbitration decision upholding the termination of a deputy sheriff for a misdemeanor domestic violence conviction. Morrison v. Warren, #02-3672, 1375 F.3d 468, 2004 U.S. App. Lexis 14291, 2004 FED App. 0223P, 175 LRRM (BNA) 2197, 21 IER Cases (BNA) 902 (6th Cir. 2004). {N/R}
     Michigan appellate court refuses to set aside an arbitrator's decision to reduce the punishment from demotion from corporal to a one-day suspension. The officer did not follow agency policy relating to a DUI traffic stop. Clay Twp. v. Montville, #248293, 2004 Mich. App. Lexis 1635 (2004). {N/R}
     Ohio Supreme Court declines to review a 2-to-1 appellate court decision that reinstated a police officer because management only terminated one of two officers involved in the incident. City of Lima v. FOP, #1-02-88, 2003 Ohio 6983, 2003 Ohio App. Lexis 6332, 174 LRRM (BNA) 2199; rev. den. 102 Ohio St.3d 1447, 2004 Ohio 2263, 808 N.E.2d 398 (2004). [2004 FP Sep]
     Massachusetts appellate court declines to overturn an arbitration award that reinstated a police officer that had filed a false incident report and also brought false criminal charges against two people that he had arrested. City of Boston v. Boston Police Patrolmen's Assn., #03-P-164, 60 Mass. App. Ct. 920, 805 N.E.2d 527, 2004 Mass. App. Lexis 336 (2004). [2004 FP Jul]
     Massachusetts appellate court upholds the right of an arbitrator to reduce a disciplinary penalty; the bargaining agreement prohibited discipline or discharge "without just cause." Boston Police Patrolmen's Assn. v. City of Boston, #02-P-883, 60 Mass. App. Ct. 672, 805 N.E.2d 80, 2004 Mass. App. Lexis 298 (2004). [2004 FP Jul]
     Ohio appellate court concludes that an arbitrator should not have reinstated an officer who notified a colleague that his family was under investigation. Summit County Sheriff v. FOP, #21303, 2003 Ohio 1133, 2003 Ohio App. Lexis 1062, 173 LRRM (BNA) 2174 (Ohio App. 9th Dist. 2003). [2004 FP Jan]
     Court sets aside an arbitrator's reinstatement ruling, because he did not consider prior disciplinary action, which was recent and uncontested, warning the grievant that further misconduct would result in his termination. City of Wilmington v. AFSCME L-1102, #19561-NC, 2003 Del. Ch. Lexis 26, 2003 WL 1530503, 173 LRRM (BNA) 2278 (Del. Ch. 2003). [2004 FP Jan]
     Michigan appeals court reinstates an arbitration award directing the city to promote a controversial officer who had shot 4 people is 6 years. Detroit Police Officers Assn. v. City of Detroit, #241574, 2003 Mich. App. Lexis 2850 (Unpub. 2003). [2004 FP Jan]
     Oregon courts affirm an arbitrator's decision to reinstate an officer who used marijuana and lied about it. Reinstatement does not offend considerations of public policy against drug use or dishonesty, and is consistent with a goal of the rehabilitation of drug users. Washington Co. Police Assn. v. Washington Co., SC#S49518, 335 Ore. 198, 63 P.3d 1167, 2003 Ore. Lexis 120, 172 LRRM (BNA) 2037 (Ore. 2003); decis. on remand, 69 P.3d 767, 2003 Ore. App. Lexis 629, 172 LRRM (BNA) 2592 (Ore. App. 2003). [2003 FP Sep]
     Rhode Island court sets aside an arbitration award reinstating a corrections officer that had threatened a coworker with physical harm. Officer had received five disciplinary suspensions in six years. The judge found that the safety of the institution is a "narrow circumstance" where an arbitration award can be set aside. Rhode Island DoC v. R.I. Bro. of Corr. Off. (Giles), #01-6344, 2003 R.I. Super Lexis 53 (2003). {N/R}
     An appeals court in Pennsylvania concludes that an arbitrator properly reduced a termination to a disciplinary suspension; a female jail clerk had a copy of Playgirl magazine in her desk drawer. Bedford County v. Penn. Soc. Servs. Union L-668, #1621 C.D. 2002, 814 A.2d 866, 2003 Pa. Commw. Lexis 24, 171 LRRM (BNA) 3038 (1/13/03). {N/R}
     Rhode Island Supreme Court reverses an arbitrator and upholds the termination of a corrections officer. The officer had been fired because a missing handcuff key was found in the possession of an inmate, with whom the officer had formed a personal friendship. State v. Rhode Island Bro. of Correctional Officers (Ryan), 819 A.2d 1286, 2003 R.I. Lexis 94 (R.I. 2003). {N/R}
     Appeals court affirms an arbitration award that reinstated a public employee who verbally threatened to kill his supervisor. City of Harvey v. AFSCME, C-31, L-2404, #1-01-1354, 2002 Ill. App. Lexis 719 (Ill. App. 1st Dist. 2002). [2002 FP Nov]
     Michigan appeals court affirms an arbitration award reinstating a jail officer. Conduct was not severe enough to warrant judicial interference. Police Officers. Assn. of Mich. v. Co. of Manistee, #226909, 250 Mich.App.339, 645 N.W.2d 713, 2002 Mich. App. Lexis 823 (Mich. App. 2002). [2002 FP Sep]
     Appeals court overturns an arbitration award that ordered reinstatement of a deputy who repeatedly used marijuana and lied about it to his superiors. Washington Co. Police Officers v. Washington County, #A114208, 181 Ore. App. 448, 45 P.3d 515, 2002 Ore. App. Lexis 727 (2002). [2002 FP Aug]
     Minnesota appellate court overturns an arbitral award that reinstated a police officer that had a long history of harassing women. City of Brooklyn Center v. Law Enf. Labor Serv., #C5-01-414, 635 N.W.2d 236, 2001 Minn. App. Lexis 1146, 168 LRRM (BNA) 2593 (Minn. App. 2001). [2002 FP Jan]
     Connecticut Supreme Court confirms an arbitration award reinstating a police officer who used poor judgment in drawing his weapon. Arbitrators are free to disagree with a psychiatric report of unfitness and to fashion special conditions for reinstatement. South Windsor (Town of) v. S.W. Police Union L-1480, #16338, 255 Conn. 800, 770 A.2d 14, 2001 Conn. Lexis 118 (2001). [2001 FP 147-8]
     Landmark Case: Supreme Court refuses to overturn an arbitrator’s reinstatement of a two-time drug abuser. The public policy of enforcing arbitral decisions trumps the policy of punishing substance abusers. Eastern Assoc. Coal Corp. v. United MWA D-17, 121 S.Ct. 462, 2000 U.S. Lexis 8083. [2001 FP 3]
    Ohio Supreme Court upholds an arbitration award that reinstated a transit worker for failing a drug test. Although employer had a zero tolerance policy for safety-sensitive employees, there was no dominant and well-defined public policy against reinstating and rehabilitating a safety-sensitive employee. Southw. Ohio Reg. Transit Auth. v. Amal. Tr. Un. L-627, #00-21, 91 Ohio St.3d 108, 742 N.E.2d 630, 2001 Ohio Lexis 461, 166 LRRM (BNA) 2873 (2001). [2001 FP 100-1]
     For a second time, an appellate court reinstates the punishment for 28 firefighters, although disciplinary action was delayed beyond the period authorized in the bargaining agreement. In so holding, the court overturned an arbitrator's award that annulled the punishment, because it was contrary to a "well defined, dominant public policy." Chicago Fire Ftrs. L-2 v. City of Chicago, #1-99-2647, 323 Ill. App.3d 168, 751 N.E.2d 1169, 2001 Ill. App. Lexis 401 (1st Dist., 2001). [2001 FP 100-1]
     Appellate court overturns arbitrator's decision to reinstate an officer who had engaged in polygamy and made false statements. The fact the criminal statute of limitations applied has no application to employment terminations. Sheriff of Lenawee Co v. Police Ofcrs. Labor Council, #211705, 239 Mich. App. 111, 607 N.W.2d 742, 1999 Mich. App. Lexis 334, 163 LRRM (BNA) 2952. [2000 FP 86-7]
     New York's highest court refuses to disturb an arbitration award exonerating a corrections officer who flew a Nazi flag outside his home. N.Y. St. Corr. PBA v. St. of N.Y., #201, 94 N.Y.2d 321, 726 N.E.2d 462, 1999 N.Y. Lexis 3933, 163 LRRM (BNA) 2239. [2000 FP 35]
     California appeals court overturns an arbitrator's award reinstating a municipal employee who threatened to kill a coworker because it would violate a court restraining order. Employer's general duty to provide workplace safety was not enough, standing alone, to overturn the award. Palo Alto v. SEIU L-715, #H019017, 91 Cal.Rptr.2d 500, 1999 Cal. App. Lexis 1128. [2000 FP 36]
     A judgment confirming an arbitrator's award may not be vacated by an appellate court unless it is violative of a strong public policy, is totally irrational, or clearly exceeds specifically enumerated limitations on the arbitrator's power. Public policy considerations weigh in favor of affirming an arbitrator's award. City of Newburgh v. Police Ben. Assn., #1999-01881, 272 A.D.2d 326, 2000 N.Y. App.Div. Lexis 4807. {N/R}
     Pennsylvania appellate court refuses to disturb an arbitrator's decision to reinstate a police officer who abused cocaine. The strong public policy supporting arbitration superseded other considerations. Philadelphia v. FOP, 711 A.2d 1060 (Pa. Commw. 1998); also see Penn Twp. v. AFSCME, 713 A.2d 1218 (Pa. Commw. 1998). {N/R}
     Federal appeals court declines to set aside an arbitration award reinstating a nuclear power plant safety officer, who failed to respond to fire alarm and then lied about incident. Elect. Wrkrs. L-97 v. Niagara MPC, 1999 U.S. App. Lexis 19575, 189 F.3d 250, 162 LRRM (BNA) 2065 (2nd Cir.). {N/R}
     Pennsylvania appeals court upholds an arbitrator's decision to increase the penalty to termination. Penna. St. Trprs. Assn. v. Penna. St. Police, 667 A.2d 38 (Pa.Cmwlth. 1995). [1996 FP 67]
     Wisconsin Supreme Court concludes that sheriffs are bound by arbitration awards and civil service decrees; they must redeputize and fully reinstate terminated deputies if so ordered. Brown Co. Sheriff's Dept. v. BCSD Employees’ Assn., 533 N.W.2d 766 (Wis. 1995). [1996 FP 35]
     State supreme court upholds a county personnel commission order to reinstate a deputy sheriff. The “unbridled power” to appoint deputies “threatens the quality of law enforcement” and “will discourage qualified candidates from seeking the position of deputy sheriff.” Heitkemper v. Wirsing, 533 N.W.2d 770 (Wis. 1995). [1996 FP 35]
     “An arbitration award will not be vacated when the arbitrator explains his decision in terms that offer even a barely colorable justification for the outcome reached, even if the arbitrator's interpretation of the contract is clearly erroneous.” Great Atlantic v. Local 338, 1996 U.S. Dist. Lexis 7207/*3 (S.D.N.Y.), quoting Meyers v. Parex, 689 F.2d 17/18 (2d Cir. 1982). {N/R}
     Federal appeals court overturns arbitration award reinstating an employee who had been discharged for repeatedly sexually harassing women coworkers. The award condoned his misconduct and “tends to perpetuate a hostile, intimidating and offensive work environment.” Further, it impedes the employer's "legal duty to eliminate sexual harassment in the workplace." Newsday, v. L.I. Typog. Union L-915, 915 F.2d 840/at 845 (2d Cir. 1990). {N/R}
     Arbitrator could reduce termination punishment to suspension; could not order department to restore law enforcement powers. Monroe Co. Sheriff v. FOP L-113, 357 N.W.2d 744 (Mich. App. 1984).
     See also: Alternative Dispute Resolution and Access to Courts, Arbitration Procedures, Collective Bargaining, Disciplinary Procedures and Impasse Arbitration.


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