Commonwealth v. Pennsylvania State Troopers Ass'n, 611 Pa. 56

Summary

The Pennsylvania Supreme Court reviewed whether an Act 111 interest arbitration award could require the Commonwealth to pay state troopers on union leave compensation designated by their union. The Court held that the award did not violate the State Employees' Retirement Code because the relevant statutory provision addressed retirement rights and did not establish a ceiling on union-leave salaries. The Court reversed the Commonwealth Court's invalidation of the union-leave provision.

Holdings

1. Section 5302(b)(2) does not impose a statutory ceiling limiting union-leave salaries to the amount a trooper would have received in full-time active service. The provision primarily governs credited service and pension-related rights and does not prohibit an Act 111 arbitration panel from awarding higher union-leave compensation.
2. Because the union-leave wage provision did not require the Commonwealth to perform an illegal act or an act it could not voluntarily undertake, the provision was within the arbitration panel's authority and was beyond judicial review under narrow certiorari.

Questions Presented

1. Whether the Act 111 interest-arbitration award's union-leave wage provision violated section 5302(b)(2) of the State Employees' Retirement Code.
2. Whether the award required the Commonwealth to perform an illegal act and therefore exceeded the arbitration panel's authority under the narrow-certiorari standard.

Disposition

reversed_and_remanded