Annapolis Professional Firefighters Local 1926 v. City of Annapolis

The City of Annapolis (defendant) maintained a collective-bargaining agreement with the Annapolis firefighters, who were represented by a labor union (the union) (plaintiff). The firefighters’ three-year contract was set to expire on June 30, 1993. Per its provisions, the contract would automatically be renewed on an annual basis until a successor agreement was executed. The contract contained provisions for handling any proposed contract changes, starting with giving notice of a desired modification. The parties were required to negotiate, then, if they reached an impasse, mediate a dispute with the state’s mediation and conciliation service, and finally resort to a neutral fact-finding process. In April 1993, the parties began negotiating a new contract. The city, for the first time, contended that lieutenants and captains in the fire department were supervisory personnel and, accordingly, not eligible for inclusion in the same bargaining unit as other firefighters. The union disagreed but maintained negotiations on other issues. After the current contract expired, the city declared that the parties were at an impasse on the bargaining-unit issue and unilaterally removed lieutenants and captains from the bargaining unit. Mediation with the state’s mediation service was not possible because the service had been eliminated due to state budget cuts. The union sued the city and, instead of asking for a mediation-related remedy, sought an injunction that would prohibit the city from unilaterally adopting its own position. The trial court declined to grant injunctive relief, and the union appealed.