Allegheny Cty Sheriffs' Ass'n v. Pa. Labor Relations Bd. (majority)
Annotate this CaseIn this case, the Supreme Court considered whether deputy sheriffs of second class counties were "police officers" for collective barganing purposes under "Act 111." The Commonwealth Court determined they are not after hearing the Allegheny County Deputy Sheriffs' Association filed a petition with the Pennsylvania Labor Relations Board (PLRB) seeking to represent the deputies employed by Allegheny County. The Association twice before had attempted to attain this same objective, only to fail before the PLRB and the Commonwealth Court. However, following those decisions, the General Assembly amended the Crimes Code in 1995, and then the Municipal Police Education and Training Law (MPETL) in 1996, to define deputy sheriffs in a second-class county (i.e., the Deputy Sheriffs) as police officers. Concluding that the aforesaid legislative action was not dispositive of the issue, the PLRB hearing examiner here determined that the Deputy Sheriffs were not "police officers" as contemplated by Act 111 because he found that their primary duties were not those of typical police officers, but rather were those directly related to the operation of the courts. "[The Supreme Court's] inquiry with respect to the question accepted for review ends with the recognition that the General Assembly expressly defined -- and thus authorized -- deputy sheriffs of counties of the second class to be police officers. . . . Thus, the PLRB’s and Commonwealth Court’s application of a judicially and administratively created test to examine whether the Deputy Sheriffs are police officers, after they have been defined as such by the General Assembly, was erroneous."
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