Employes of the City of Philadelphia v. Pennsylvania Labor Relations Board

In Employes of the City of Philadelphia v. Pennsylvania Labor Relations Board, 23 Pa. Commw. 233, 350 A.2d 923 (Pa. Cmwlth. 1976), appeal denied, (No. 2390 Allocatur Dkt. 1976, filed May 25, 1976), the Court held that the PLRB lacks jurisdiction over "questions of recognition." In Employes, the City's deputy sheriffs sought exclusive and separate representation by the Fraternal Order of Police, Lodge No. 5 (FOP), i.e., the deputy sheriffs wanted the PLRB to "recognize" the FOP as their exclusive bargaining representative. The Court held that the PLRB lacked jurisdiction because the deputy sheriffs were required to be represented by AFSCME under section 2003 of PERA and the 1961 Ordinance.