Where plaintiff police officers brought suit against the defendant city for deducting a 10 percent administrative fee from wages they received for police detail work, a judgment in favor of the officers should be reversed based on unambiguous language in the parties’ collective bargaining agreement.
“This appeal follows a bench trial involving police officers in the City of Malden (collectively, ‘Officers’) and the City of Malden (the ‘City’). The Officers brought suit against the City for allegedly deducting a ten percent administrative fee from wages they received for police detail work. At the heart of the lawsuit was a term in the Collective Bargaining Agreement (‘CBA’) that set the hourly rate for police detail work — a term that the parties interpreted differently. The Officers presented their interpretation of the term, which aligned with how the Officers were historically paid. The contract term was crucial to the case because the Officers claimed that a ten percent deduction for an administrative fee resulted in a reduction in their wages — as set forth in the CBA — thereby violating the Massachusetts Wage Act, Mass. Gen. Laws ch. 149, §148 (the ‘Wage Act’). The City, however, argued that the CBA set a lower rate than the Officers were paid, so any reduction in the calculated rate still resulted in a higher payout than contemplated in the CBA.
“At trial, the district court concluded that the contract term was ambiguous and extrinsic evidence was required to...
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