County of Chautauqua v. Civil Service Employees Association, Local 1000, AFSCME

Chautauqua County (county) (defendant) officials determined that layoffs were necessary for economic reasons. But the officials perceived a conflict between state law and the collective-bargaining agreement (CBA) with the Civil Service Employees Association, Local 1000, AFSCME (union) (plaintiff). Specifically, state law required layoffs by seniority within a position, which would allow a government employer to eliminate a position even if the position were held by employees more senior than employees in a different position. By contrast, the CBA required layoffs by seniority only, regardless of whether a position should be eliminated. The county followed the state law. The union filed a grievance, claiming that the county violated the CBA by refusing to (1) lay off employees with the least seniority first, regardless of position, and (2) allow senior employees in one department that was experiencing layoffs to displace less-senior employees in another department that was not experiencing layoffs. The county responded that these matters were not arbitrable because they were contrary to state law. The trial court determined that the first matter was not arbitrable because it was contrary to state law but that state law did not address the second issue, making it arbitrable. The intermediate appellate court reversed in part, concluding that both issues were arbitrable.