AMERICAN FEDERATION OF
GOVERNMENT EMPLOYEES. AFL-CIO
Bobby L. Harnage
National President
National Secretary-Treasurer
Andrea E. Brooks
Director, Women’s/
Fair Practices Departments
January
23, 2003
Ms. Carolyn
Federoff
President,
Council 222
PO Box 5961
Boston,
MA 02 114
Pursuant to
the request of HUD Council 222 this office
has carefully reviewed the final Federal Labor Relations Authority
decision in AFGE C-222 and HUD, 58 FLRA No. 51 (Nov. 29, 2002). The
FLRA decision at issue arose from the review of an arbitration award of Roger Kaplan issued on June 24, 2002. Any appeal to the Court of
Appeals must be filed before February 27, 2003.
Our review of AFGE C-222 and HUD
is informed by 5 U.S.C. §7123 (a) which. mandates what FLRA decisions are
allowed to be appealed into court in very limited circumstances. Final
decisions of the FLRA involving arbitrator's awards are not subject to judicial
review where no Unfair Labor Practice was involved. NTEU v. FLRA, 112
F.3d 402, 404 (9th Cir. 1997). A final decision of the FLRA that
reviews an arbitration award "[is] absolutely immune from judicial
review". U.S. Dept of Treasury, U.S. Customs Service v. FLRA,
43 F.3d 682, 686 (D.C. Cir. 1994).
The grievance
before the arbitrator arose from a career ladder dispute for Community Builders
(CB), a position with either a GS-13 -15 career ladder or individual positions
classified as GS-13, 14, or 15 (that is the dispute). In June 2000 the Union
filed a grievance challenging an alleged change from the GS-13-15 career ladder
to individual positions being rated in
a GS-13-15 range. On March 16, 2001 (further amended) the parties signed a
settlement agreement of the June 2000 grievance providing for a review of CB
promotions. This review was completed by the Agency and the Union filed the
current grievance asserting that the Agency failed to provide retroactive
promotions and back pay to CBs.
Carolyn Federoff
January 23, 2003
Page 2
In this case the issue
before the arbitrator, as stipulated by the parties, was as follows:
1. Did the Department properly
implement the March 16, 2002 Settlement Agreement, as amended?
2. If not,
what is the appropriate remedy?
In his
decision the arbitrator identified the issue as follows:
This grievance involves a challenge to the propriety of the implementation of the Settlement Agreement.
Arb. Dec. pg. 9.
Neither the issue presented to
the arbitrator nor the arbitrator's award mentions an Unfair Labor Practice.
When a union utilizes the grievance procedure under a collective bargaining
agreement, and not as an Unfair Labor Practice, the union has to accept
the consequences of that position and is not be permitted to transform a
grievance claim into a statutory claim. Regrettably, the courts simply have no
jurisdiction over the appeal from the CB arbitration award or FLRA decision. AFGE
L-916 v. FLRA 951 F.2d 276, 279 (l0th Cir. 1991). This lack of jurisdiction
remains even if the violation by the Agency could have originally been
raised as a ULP. U.S. Marshals Service v. FLRA, 708 F.2d 1417, 1420-21
(9th Cir. 1953).
On exceptions, the final
decision of the FLRA in this case is a cursory form denial of cross exceptions
to the arbitrator's award based upon the parties' failure to raise an
appealable issue. Again, the FLRA makes no mention of a ULP. Therefore,
pursuant to 5 U.S.C. §7123(a) there is no appeal, as a matter
of law, of the final decision of the FLRA affirming the underlying arbitration
award.
We have
reviewed the Union's allegations that the Agency has taken contrary factual
positions on this situation in different fora However, even assuming that the
Agency has been inconsistent (or indeed contrary) as to the career ladder
status of CBs, the Agency's inconsistency does not provide a basis
for judicial review of a final FLRA decision of an arbitration award that
does not involve a ULP.
I know this is an important
issue for the Council and we have, looked for any possible
"thread" upon which to base a non-frivolous court appeal, however,
there simply is none. Thirty years of. legal precedent under the Civil Service
Reform Act makes it clear that the FLRA's decision in 58 FLRA No. 51 is final
and binding.
January
23, 2003
Page
3
I am sorry a more favorable
decision cannot be rendered but the law clearly prohibits any further appeal in
this case. As an aside, I received about a dozen identical petitions from CBs
urging me to appeal this decision, I will be writing them individually as to
why an appeal is not legally possible.
Sincerely and fraternally,
Mark D. Roth General Counsel
cc: Council 222 Executive Board and Local Presidents
c/o President Federoff