Supreme Court of Alaska affirms superior court’s holding that municipal code limited its equitable power to impose contract conditions as part of a permanent injunction in collective bargaining dispute.
Union and municipality entered into collective bargaining to renew the union’s expiring contract. When negotiations broke down, the parties entered into arbitration, but the arbitrator’s proposed decision failed to garner the necessary municipal assembly votes to become binding on the parties.
Under the municipality’s labor ordinances, the assembly’s failure to approve the arbitrator’s decision resulted in an impasse, with each party given a remedy: the municipality could implement its last best offer presented at arbitration, and the union could go on strike. However, the union’s statutory right to strike was limited and could be enjoined if the work stoppage threatened public health and safety.
Although the union voted to strike, it agreed to a preliminary injunction before the strike was scheduled to begin because work stoppage would threaten public health and safety almost immediately. The union then argued that the superior court should impose the arbitrator’s decision as a condition of a permanent injunction to compensate for “taking away” the union’s right to strike.
The superior court held that its equitable jurisdiction was constrained by the municipal code, which had no provision for imposing the arbitrator’s decision, and entered an order permanently enjoining the strike and allowing the municipality to implement its last best offer. The union appealed, arguing the superior court erred as a matter of law in holding the municipal code limited its equitable power to impose contract conditions as part of a permanent injunction.
The Supreme Court of Alaska affirmed the superior court’s decision.