Great Falls v. Assoc. of Firefighters
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The City of Great Falls unilaterally revised its drug and alcohol policy in 2019, expanding the scope of employees subject to random testing and imposing stricter penalties without negotiating with the affected labor unions. The unions filed unfair labor practice complaints, alleging that the City's actions violated the Montana Public Employees Collective Bargaining Act (MPECBA). The Montana Board of Personnel Appeals (MBPA) consolidated the complaints and referred them to a hearing examiner, who ruled in favor of the unions, concluding that the City's unilateral policy changes constituted unfair labor practices.
The City did not file exceptions to the hearing examiner's proposed decision, which became the final agency decision by default. Instead, the City petitioned for judicial review, arguing that the hearing examiner's decision involved purely legal questions that should be reviewed by the court. The District Court of the Eighth Judicial District, Cascade County, dismissed the petition, citing the City's failure to exhaust administrative remedies by not seeking final agency review.
The Supreme Court of the State of Montana reviewed the case and affirmed the District Court's decision. The Court held that the City's failure to exhaust the final agency review remedy provided by MPECBA and the Montana Administrative Procedure Act (MAPA) precluded judicial review. The Court clarified that there is no jurisprudential exception to the exhaustion requirement for purely legal or constitutional questions in the context of MAPA contested case proceedings. The City's petition for judicial review was thus correctly denied and dismissed.
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