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City of Boston Prevails in Quinn Bill Decision

On March 7, 2012, the Supreme Judicial Court (SJC) ruled in favor of the City of Boston in a case brought by police officers seeking additional payments under the Quinn Bill, M.G.L. c. 41, § 108L.  The Quinn Bill provides police officers of adopting municipalities salary increases based on law enforcement-related academic degrees obtained.  Under the statute, participating municipalities’ police officers “shall be granted” salary increases paid out by the municipalities, which “shall be reimbursed” by the Commonwealth for 50% of the payments made.

Because the Commonwealth has in recent years failed to appropriate funds sufficient to cover its 50% share, the City and its police unions entered into collective bargaining agreements that specifically limited the City’s Quinn Bill costs to its statutory 50% share, plus any amount actually reimbursed by the Commonwealth.  The police officers brought suit alleging that these contract provisions illegally conflict with the Quinn Bill, which they viewed as requiring the City to pay 100% of the benefits regardless of reimbursement, which is subject to appropriation by the Legislature.

The SJC rejected the officers’ arguments.  Based on its language and legislative history, the Court concluded that the Quinn Bill has two objectives:  to improve police officers’ education levels (accomplished through salary increases) and to give municipalities the ability to fund the salary increases at twice level they could otherwise afford (accomplished through reimbursement).  In the SJC’s view, requiring the City to pay 100% of the benefit promotes only the goal of better educated police and ignores the shared funding scheme.

The Court thus ruled that in order to effectuate both statutory purposes, the payment provision must be viewed as contingent on reimbursement and that, therefore, the Quinn Bill only requires municipalities to pay 50% of the salary increases, plus any amount received as reimbursement.  Because this is precisely what the City’s collective bargaining agreement provisions required, the Court concluded that the contracts are consistent with the Quinn Bill and therefore valid and enforceable.

Kay Hodge, Esq. and John Simon, Esq. represented the City of Boston in this case.