A grievance that was not immediately filed, within 10 business days of an event that gave rise to the grievance, can be saved as a result of the continuing course of conduct doctrine. Douglas Hall represented the union, and Michael Rose represented the municipality. On July 1, 2010, the Town of Rocky Hill reduced the work hours of an employee, Sarravich Minakan, and Minakan was required to pay a higher premium for health insurance. On March 30, 2011, the union filed a grievance. The municipality objected that the grievance was not filed timely, within 10 working days of July 1, 2010. The collective bargaining agreement provides, "In order to be valid, a grievance must be filed in writing 10 working days from the event giving rise to the grievance." The union claimed that under the continuing course of conduct doctrine, there was a continuing violation, each time that the grievant received a paycheck that included the deduction for health insurance. Arbitrators voted, 2-1, that the grievance was filed timely and was arbitrable. "Paychecks made in violation of a contract," wrote the majority of arbitrators, "provide a basis for the application of the continuing course of conduct doctrine." Arbitrators concluded that the grievance was arbitrable and was restricted to the date of the grievance.

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