Metro Dade Firefighters, International Association of Fire Fighters, Local 1403 v. Miami-Dade County
The Third DCA reversed a circuit court order vacating a labor arbitration award that required Miami-Dade County to restore eleven years of a retired firefighter's sick leave under a CBA provision incorporating the County's Service-Connected Disability Program. Because the arbitrator decided precisely the issues submitted — including a remedy question the County itself framed — he did not exceed his powers under section 682.13(1)(d), and any error of law in interpreting the incorporated ordinance was not a ground for vacatur.
Key facts
- Metro Dade Firefighters union and Miami-Dade County submitted a labor dispute to arbitration regarding a retired firefighter's sick leave entitlements under a collective bargaining agreement incorporating the County's Service-Connected Disability Program.
- The arbitrator ruled that the County must restore eleven years of the firefighter's sick leave based on his interpretation of the incorporated ordinance and CBA provisions.
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Why it matters
A useful reminder that Florida courts cannot police the merits of arbitration awards: even an arguably erroneous interpretation of a contractually incorporated ordinance survives review so long as the arbitrator… — full analysis with a trial
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