City of Philadelphia v. Fraternal Order of Police Lodge No. 5

Justice EAKIN,

dissenting.

I respectfully dissent, as I disagree with the majority’s characterization of the Act 111 arbitrator’s sanction as a constitutional due process violation. Act 111 was designed to ensure timely resolution of grievances by police officers and firefighters; thus, the Act only permits appeals from an arbitrator’s decision under very limited circumstances. See Pennsylvania State Police v. Pennsylvania State Troopers’ Association (Betancourt), 540 Pa. 66, 656 A.2d 83, 89 (1995) (swift resolution of labor disputes decreases chance public safety workforce will be destabilized by protracted litigation; legislature’s intent was to prevent Act 111 arbitration awards from miring down in litigation). Permitting a party to challenge what amounts to a routine evidentiary ruling is to thwart Act Ill’s purpose.

*293Here, the arbitrator imposed a sanction on the City for its admitted discovery violation; the sanction was the preclusion of evidence not turned over as required. The fact that this ruling excluded all the City’s evidence reflects only the fact that the City failed to provide the entirety of its evidence in the first place. That is, the de facto magnitude of the remedy mirrors the de facto magnitude of the City’s failure — the scope of the ruling is simply commensurate with the violation, regardless of the consequence to the City’s case. That consequence does not alter the ruling’s nature; it was a decision pertaining to the admission or exclusion of evidence, which is within the arbitrator’s discretion. See AFSCME District Council 88 v. County of Lehigh, 798 A.2d 804, 808 (Pa.Cmwlth. 2002).

Classifying such a ruling as one of constitutional magnitude because the City withheld all its evidence is to allow the tail to wag the dog; an evidentiary ruling does not become a due process matter simply because its encompassing scope matches the encompassing nature of the violation. To allow such challenge to an arbitrator’s sanction, even under these circumstances, disrupts the deference Act 111 arbitrators’ decisions are due, see 43 P.S. § 217.7(a) (“No appeal therefrom shall be allowed to any court.”), and will result in awards being mired down by challenges to routine rulings.

I appreciate the City’s ultimate compliance, but the question before this Court is the scope of review, not the equities of the ruling. Accordingly, I would hold Betancourt does not authorize narrow certiorari review of the arbitrator’s evidentiary sanction. I would reverse the Commonwealth Court’s order remanding for full arbitration, and would reinstate the arbitrator’s decision sustaining the grievance and reinstating the grievant to the police force.

Justice McCAFFERY joins this dissenting opinion.