Garcia v. City of Hartford
As the Connecticut Supreme Court made clear in the 2009 case of Honulik v. Greenwich, "[p]rinciples of contract law guide [the] interpretation of collective bargaining agreements." Edwin Garcia resigned from the Hartford Police Department after completing over 16 years of service and accumulating 80 unused sick days. Garcia was ineligible to receive retirement benefits because he had not yet reached the 20th anniversary of his hire date as required under the relevant collective bargaining agreement between the city and the Hartford Police Union. Once he began receiving benefits after the 20th anniversary of his hire date, he requested to trade in accumulated sick time for increased pension benefits. The request was denied. Garcia filed a complaint seeking damages and the issuance of two writs of mandamus ordering Hartford treasurer, Kathleen Palm, and the Hartford Pension Commission to allow Garcia to apply 80 days of accumulated sick time toward increased pension benefits and Santiago Malave, director of personnel, to certify the exact amount of accrued sick time accumulated. The trial court dismissed the complaint for lack of jurisdiction for failure to exhaust administrative remedies. The Supreme Court reversed the judgment. On remand, the trial court rendered judgment for the defendants. The plaintiff appealed claiming that the trial court incorrectly determined that the controlling collective bargaining agreement prohibited the plaintiff from applying 80 accumulated sick days toward a pension benefit enhancement once the plaintiff reached the 20th anniversary of his hire date. The Appellate Court disagreed and affirmed the judgment. The trial court properly determined that the plaintiff did not qualify to exchange his accumulated sick time in return for increased pension benefits. The court properly refused to issue the writ of mandamus to compel the defendants to allow him to exchange his accumulated sick time because he did not satisfy the requirements for mandamus and did not show a clear legal right as to the benefits. The collective bargaining agreement only allows those who qualify or become qualified for normal retirement benefits after 20 years of continuous service to participate in the accumulated sick time exchange for increased pension benefits. Although the plaintiff qualified to receive pension benefits, he did not qualify or become qualified to receive normal retirement benefits under the agreement.