Bisch v. Las Vegas Metro. Police Dep't
Annotate this CaseA police department initiated an internal investigation of Appellant, a veteran of the department, regarding allegations of insurance fraud. During an internal investigation meeting, Appellant was not provided a police protective association (PPA) representative because she had retained a private attorney. Appellant subsequently received a formal written reprimand. Appellant later filed a complaint with the Employee Management Relations Board (EMRB) against the PPA and the department. The EMRB denied Plaintiff's claims, and the district court denied Appellant's petition for judicial review. The Supreme Court affirmed, holding (1) the EMRB correctly concluded that Nev. Rev. Stat. 289.080 did not impose a duty of fair representation on the PPA, and thus, Appellant was not entitled to have PPA representation present during the internal investigation meeting; and (2) the EMRB properly upheld the department's written reprimand of Appellant.
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