A municipality has just cause to issue a written warning, if the municipality substantiates claims of poor work performance. On Nov. 17, 2011, the Town of Wallingford issued a written warning to Karen Wasilewski, who worked as a clerk for the Department of Engineering, alleging that her work included factual errors and typos and that she needed to improve her performance, productivity and attitude. Previously, the town had issued a verbal warning and counseled Wasilewski. The union filed a grievance and argued that a manager retaliated against Wasilewski, because she complained about the manager to human resources. Arbitrators found that the municipality substantiated its claims of poor work performance and it had just cause to issue a written warning. Dennis Ciccarillo represented the municipality, and Patrick Sampson represented the union.