Firefighters union brought declaratory judgment action against city, seeking ruling that quorum of city counsel was required to negotiate with union, that city could not unilaterally decide to conduct negotiating sessions in public, and that proposals exchanged by parties during negotiations were not public records. The District Court granted summary judgment in favor of city. Union appealed.
The Supreme Court of Wyoming held that:
- Quorum of city counsel was required to negotiate with firefighters union regarding terms of parties’ collective bargaining agreement;
- Union’s claim seeking declaration that collective bargaining sessions between union and city were required to be held in executive session did not present justiciable controversy under Uniform Declaratory Judgments Act (UDJA); and
- Union’s claim seeking declaration that proposals exchanged by city and union during collective bargaining sessions were exempt from disclosure under Public Meetings Act did not present justiciable controversy under UDJA.
Under statute obligating the city through its “corporate authorities” to meet and confer in good faith with representatives of fire fighters’ bargaining agent, quorum of city counsel was required to negotiate with firefighters union regarding terms of parties’ collective bargaining agreement, and neither the mayor nor a single councilman were corporate authorities authorized to negotiate with union. To be considered corporate authorities, officials were required to be elected or appointed by inhabitants of the city and have power to establish wages, working conditions, and other conditions of employment of fire fighters, but neither mayor nor single councilman had power to establish wages, working conditions, or other conditions of firefighters’ employment, so quorum of city council members was required to negotiate with union.