An Illinois Appellate Court recently ruled in favor of a City in a case brought by a police officer who claimed the City failed to comply with the Public Employee Disability Act (PEDA) after he was injured. Allenbaugh v. City of Peoria.
A police officer filed a lawsuit against a City claiming the City failed to comply with the terms of PEDA by denying him full pay after he was injured in the line of duty. The City argued the trial court had no jurisdiction over the officer’s claim because the dispute was governed by the City’s collective bargaining agreement (CBA). Specifically, the City argued that because the officer’s claim would require an interpretation of the meaning of specific language contained in the CBA, it had to be resolved through the exclusive grievance procedure contained in that CBA. The officer argued that because the lawsuit involved a claim that the City violated state law, the court had jurisdiction over the claim. The trial court ruled in favor of the City, finding that because resolution of the officer’s PEDA claim depended on an interpretation of the CBA, it was subject to the mandatory grievance provisions of that agreement.
On appeal, the Appellate Court agreed with the trial court that resolution of the dispute turned on an interpretation of the language in the CBA, and so the claims brought by the officer were subject to the exclusive grievance provision of the CBA. As a result, the Appellate Court upheld the ruling in favor of the City.