Local 1219, I.A.F.F. v. Connecticut Labor Relations Bd

In Local 1219, I.A.F.F. v. Connecticut Labor Relations Bd., 171 Conn. 342, 370 A.2d 952 (Conn. 1976), a firefighter union and a municipal employer entered into a three-year collective bargaining agreement. The agreement provided that "it is understood and agreed that if the borough grants to the police department any additional benefits over and above this contract and during its term, the employees in this bargaining unit will be granted the same additional benefits . . . ." 370 A.2d at 955. After the municipality refused to give the same additional benefits to the firefighters that it gave police officers, the union initiated a grievance procedure before the board of mediation and arbitration. The board ultimately refused to enforce the parity provision, and this decision was affirmed by the trial court. The Connecticut Supreme Court agreed, and held that the parity provision was unenforceable. In reaching its decision, the Court relied on Conn. General Statute 7-468(a), which provided that employees have the right "to bargain collectively . . . on questions of wages . . . free from . . . interference, restraint or coercion," and Conn. General Statute 7-471(3), which required employees of municipal fire and police departments to be in separate collective bargaining groups. The Court reasoned that the police union's right to bargain has been completely taken from it. By voiding parity clauses in circumstances similar to those found in the present case, the defendant board preserves the wall of separation mandated by the statute. The board's action will also ensure that the units will be allowed to tie themselves to a rule of equality only if each unit agrees with the other that their interests are the same. Id. at 957.