Public Case No. R 1989-018
International Association of Fire Fighters, Local 2665, AFL-CIO v.
Eureka Fire Protection District, Eureka, Missouri
IAFF filed for certain employees of the Eureka Fire Protection District. The sole contested issue before the Board was whether the District’s Captains and Lieutenants should be excluded from the bargaining unit as supervisors. The Board concluded that Captains were supervisors, but Lieutenants were not.
In concluding that Captains were supervisors, the Board noted their input in the hiring, promotion, and discipline decisions. They investigate suspected improper conduct and may impose verbal and written reprimands. The Captains also exercise independent judgment and discretion in directing and assigning Fire Fighters because they are often the highest ranking officers on duty. The Board concluded that while Captains only supervised a small number of workers, this factor was not conclusive, and was counterbalanced by other considerations. The Board also noted the pay differential between Captains and other Fire Fighters, and the special training Fire Fighters received.
Applying the same criteria to the position of Lieutenant, the Board concluded that they were not true supervisors. The factors which were present in favor of the supervisory status of Captains were not present in favor of Lieutenants. The Board found no substantial differences between Lieutenants and other Fire Fighters.
The Board issued its decision excluding Captains, but including Lieutenants.
Date Issued: October 16, 1989