Plumbers & Pipefitters, Local 367 v. Municipality of Anchorage

Summary

The Alaska Supreme Court affirmed a superior court order permanently enjoining a strike by Class A.2 municipal employees whose work affected Anchorage’s water and sewage systems. The court held that the Anchorage Municipal Code limited the superior court’s equitable authority and did not permit imposition of an interest-arbitration award when the Anchorage Assembly failed to approve it.

Holdings

1. A court exercising equitable jurisdiction may not intrude into matters fully governed by the Anchorage Municipal Code or use equity to accomplish indirectly what the code prohibits directly. Because the municipal code comprehensively regulates collective bargaining, arbitration, impasse, and strike injunctions, the superior court's equitable authority was limited by that code.
2. The superior court could not impose the interest-arbitration award as a condition of the permanent injunction because AMC 03.70.110.C.10.b required approval by at least eight Assembly members before the award could bind the parties, and the award received only seven votes.
3. The municipal code's requirement that the court consider the 'total equities' applies only to the discrete question whether a Class A.2 strike should be enjoined; it does not authorize the court to impose an arbitration award or otherwise resolve the parties' bargaining dispute.
4. The Anchorage Municipal Code does not require courts to substitute binding arbitration whenever a Class A.2 employee strike is enjoined.

Questions Presented

1. Whether the superior court could exercise broad equitable jurisdiction to impose the interest-arbitration award as a condition of permanently enjoining the union's strike.
2. Whether the Anchorage Municipal Code's requirement that the Assembly approve an interest-arbitration decision before it becomes binding barred the court from imposing the award through equitable relief.
3. Whether the municipal code's requirement that a court consider the 'total equities' when deciding whether to enjoin a Class A.2 strike authorized the court to impose substantive bargaining terms beyond the injunction itself.
4. Whether the municipal code required substitution of binding arbitration whenever a Class A.2 employee strike was enjoined.

Disposition

affirmed