Municipal Collective Bargaining Agreement as to Health Insurance Premium Contribution Rates is Overridden by State Statute

In re Ridgefield Park Bd. of Educ., 244 N.J. 1 (2020). The question in this case was whether health insurance premium contribution rates for members of the Ridgefield Park Education Association (“the Association”) were non-negotiable because the subject was pre-empted by state legislation known as Chapter 78. The Association entered into a collective bargaining agreement that specified contribution rates, but thereafter the Public Employment Relations Commission (“PERC”) ruled in a case involving a different municipality that Chapter 78 pre-empted a negotiated agreement regarding contribution rates. PERC reiterated that ruling here, but the Appellate Division reversed in an opinion reported at 459 N.J. Super. 57 (App. Div. 2019), discussed here.

Today, by a 6-1 vote, the Supreme Court reversed the Appellate Division and held that Chapter 78 pre-empted the negotiated agreement. Justice Patterson wrote the majority opinion, which concluded that the plain language of Chapter 78 showed the Legislature’s intent. The majority also analyzed the legislative history and determined that it pointed to the same result. Finally, the Court rejected the Appellate Division’s view that PERC’s interpretation created an “absurd result” in the particular circumstances of this case.

Justice Albin’s dissent saw nothing in either the statutory language or the legislative history that required the result reached by the majority. He would have upheld the contribution rates that the Association negotiated with the local Board of Education.