In a compelling legal battle that underscores the complexities of employment law and collective bargaining agreements, the Village of Steger has been ordered to reinstate a terminated police officer. The Illinois Fraternal Order of Police Labor Council filed the complaint in the Circuit Court of Cook County on August 15, 2024, against the Village of Steger.
The case revolves around Ronald Woodson, a police officer who began his tenure with the Village on April 18, 2019. Under the collective bargaining agreement (CBA) effective from November 6, 2018, Woodson was considered a probationary employee for eighteen months. During this period, he was injured while on duty in January 2020. Despite his injury preventing him from performing his duties, the Village continued to pay him until September 2020 when an independent physician recommended surgery and an additional six months of recovery. Five days later, Woodson was terminated by the Village.
The very next day, the Illinois Fraternal Order of Police Labor Council (FOP) filed a grievance alleging that the Village violated Section 16.1 of the CBA by failing to pay disability benefits to Officer Woodson as mandated by the Public Employee Disability Act (PEDA). The grievance proceeded to arbitration where it was determined that despite Woodson's probationary status, he was entitled to disability benefits under PEDA because he was still considered a full-time employee. The arbitrator found that terminating Woodson's employment nine months after his injury violated both PEDA and the CBA and ordered that Woodson be reinstated.
The Village subsequently petitioned to vacate this arbitration award in circuit court, arguing that reinstatement exceeded what PEDA required and contravened public policy. However, Justice Ocasio delivered a judgment affirming that the arbitrator acted within their authority as derived from interpreting the CBA and did not violate public policy. The circuit court supported this decision by referencing an unpublished but persuasive decision in "Village of Bolingbrook v. Metropolitan Alliance of Police," which upheld similar employment protections under PEDA.
On appeal, the Village contended that enforcing such an arbitral award contravened explicit public policy and criticized reliance on unpublished decisions for judicial support. However, reviewing de novo, it was determined that neither argument held merit since unpublished orders post-January 1, 2021 can be cited for persuasive purposes under Illinois Supreme Court Rule 23(e). Furthermore, it was concluded that there is no inherent public policy limiting disability benefits strictly to pay without maintaining employment status during recovery.
Ultimately, this case highlights how collective bargaining agreements and statutory protections like PEDA work together to safeguard employees' rights even during probationary periods or when facing significant injuries. It also underscores judicial reluctance to overturn arbitration awards unless they clearly violate established public policies.
Representing these parties were attorneys whose names were not disclosed in this document summary. Presiding over this case were Justices Ocasio, Rochford, and Hoffman with Judge Caroline Kate Moreland overseeing proceedings at the Circuit Court level under Case ID No. 2022 CH 10814.