ORD 34644 - Settlement of lawsuits re fire department call-back litigation •
•
�tAAHA,N�,
, P's� RECEIVED Law Department
�► �a.. Omaha/Douglas Civic Center
z 8 tUL . All 1« 8 1819 Farnam Street,Suite 804
c+®. CL Xs J Omaha,Nebraska 68183 0804
(402)444-5115
OI?TFu FEB03t". 'w �~�-"l` Telefax(402)444-5125
City of Omaha Paul D.Kratz
Hal Daub,Mayor City Attorney
Honorable President and
Members of the City Council,
The attached Ordinance is submitted at the request of the City Law Department. It directs and
authorizes the Law Department to use the statutory procedures to allow judgment to be entered
against the City of Omaha and conclude ten lawsuits presently pending in the District Court of
Douglas County,Nebraska. If the Ordinance is approved,the City Law Department will submit an
offer to allow judgment to be taken against the City in the amount of$1,350,000.00, collectively
among the lawsuits, together with pension and Medicare contributions required of the City. The
total judgment is limited to no more than $1,572,750.00. Payment would be made from the
Judgment Fund.
These class action cases contend that the Omaha Fire Department administration violated the Fire
Union collective bargaining agreement in the manner in which persons above the firefighter rank
were called back to service. On August 8, 1996, the Honorable Judge James Murphy entered an
order finding that the City was in violation of the agreement. Trial on the damages has not been
held.
The representative plaintiffs in the cases have agreed to settle the dispute upon the terms set out in
the attached Memorandum of Understanding. If this Ordinance is approved, an offer of judgment
will be made and accepted. A judgment will then be entered by the court and payment made to each
individual. At that time, individual members of the classes may refuse to accept their payment and
appeal the judgment. If these individuals prevail on appeal, their claims will be tried but the
outcome will not affect any claim of any person accepting payment under this settlement.
Your favor consideration of this Ordinance is respectfully requested.
Res ctful,1 sub itted, Referred to the City Council for Consideration:
mas O. Mum aar `/21/f9
Assistant City Atto Mayor's Office/Title
Ap roved as to Funding:
Louis A. D'Ercole
Acting Finance Director
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ORDINANCE NO. 3 5/ yy'
AN ORDINANCE to authorize the Omaha Law Department to make an offer to allow judgment
to be taken against the City in the amount of$1,350,000.00, plus pension and medicare
contributions, in ten legal actions currently pending in the District Court of Douglas County,
Nebraska, commonly referred to as the "Fire Department call-back litigation";to approve an
agreement for payment of such judgments from appropriations of more than one fiscal year;
and to provide an effective date hereof.
WHEREAS, class action litigation is presently pending in the District Court of Douglas
County,Nebraska, entitled Russell Matsunami and Randall Hoke v. City of Omaha, Doc. 948,No.
419; Michael D. Moran and John M. Johanek v. City of Omaha, Doc. 948, No. 420; Donald L.
Carrell and John P. Goessling v. City of Omaha, Doc. 948,No. 422; Perry L. Guido, Douglas B.
Lloyd, Richard D. Hiatte and Leslie Pennington v. City of Omaha, Doc. 948,No. 423; Steven G.
Freyer and Thomas J. Olig v. City of Omaha, Doc. 948,No. 424; Russell Matsunami and Randall
J. Hoke v. City of Omaha, Doc. 959,No. 855; Michael D. Moran and John M. Johanek v. City of
Omaha,Doc 959,No. 856; Donald L. Carrell and John P. Goessling v. City of Omaha, Doc. 959,
No. 857; Perry L. Guido, Douglas B. Lloyd, Richard D. Hiatte and Leslie Pennington v. City of
Omaha,Doc. 959,No. 858;and Steven G.Freyer and Thomas J. Olig v. City of Omaha, Doc. 959,
No. 859,wherein the plaintiffs contend the City violated rights secured by the collective bargaining
agreement between the City and the Professional Firefighters Association of Omaha, Local 385,
pertaining to call-back procedures; and,
WHEREAS, the allegations of these plaintiffs and the contentions of the City of Omaha
constitute disputed claims; and,
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Ordinance No. 3 "V
Page 2
WHEREAS, this City Council finds it is in the best interest of the City of Omaha and the
residents thereof to resolve this litigation by offer of judgment in accordance with the provisions of
Section 25-901 of the Revised Statutes of the State of Nebraska; and,
WHEREAS,the parties to the legal actions have agreed to certain terms and conditions upon
which these disputed claims may be resolved which terms and conditions are set out in the attached
Memorandum of Understanding.
BE IT ORDAINED BY THE CITY COUNCIL OF THE CITY OF OMAHA:
Section 1. THAT,the City of Omaha Law Department is authorized and directed to prepare
and submit to plaintiffs an offer of judgment in the cumulative amount of$1,350,000.00, plus
pension and Medicare contributions, in the pending litigation entitled Russell Matsunami and
Randall Hoke v. City of Omaha,Doc. 948,No.419;Michael D. Moran and John M. Johanek v. City
of Omaha,Doc. 948,No.420;Donald L. Carrell and John P. Goessling v. City of Omaha,Doc. 948,
No. 422; Perry L. Guido, Douglas B. Lloyd, Richard D. Hiatte and Leslie Pennington v. City of
Omaha,Doc. 948,No. 423; Steven G. Freyer and Thomas J. Olig v. City of Omaha, Doc. 948,No.
424; Russell Matsunami and Randall J. Hoke v. City of Omaha, Doc. 959, No. 855; Michael D.
Moran and John M. Johanek v. City of Omaha, Doc 959,No. 856; Donald L. Carrell and John P.
Goessling v. City of Omaha, Doc. 959, No. 857; Perry L. Guido, Douglas B. Lloyd, Richard D.
Hiatte and Leslie Pennington v. City of Omaha, Doc. 959, No. 858; and Steven G. Freyer and
Thomas J. Olig v. City of Omaha,Doc. 959,No. 859,provided,however,that in no event shall the
total amount of the judgments exceed$1,572,750.00; and, if such offer of judgment is accepted by
plaintiffs and judgment is entered, the Finance Department shall issue such warrants as are
necessary; said funds to be paid from the Judgment Fund.
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Ordinance No. 3 /d yy
Page 3
Section 2. That the attached Memorandum of Understanding pertaining to this litigation is
hereby approved retroactive to the date of signature.
Section 3. This Ordinance is not legislative in character and shall be in full force and take
effect immediately upon passage under and by virtue of the authority granted by Section 2.12 of the
Home Rule Charter of the City of Omaha, 1956, as amended.
INTRODUCED BY COUNCILMEMBER
APPROVED Y:
l �
' 41r1
OR OF THE CITY OF OMAHA D T
PASSED AUG 1 1 1998 7-0
ATTEST:
ti
LERK F 1' ITY OF OMAHA o TE
APP OV AS TO FO .
--Z8"1e
ASSISTANT CIT ORNEY DATE
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MEMORANDUM OF UNDERSTANDING
This Memorandum of Understanding is made by and between the City of Omaha,Nebraska,
(hereinafter referred to as "the City") and the class representatives in certain class-action lawsuits,
identified below, now pending in the District Court of Douglas County, Nebraska (hereinafter
referred to as "plaintiffs"). Unless the context suggests otherwise, reference to "the City" shall
include its elected officials, employees, agents, and officers.
WHEREAS, plaintiffs have claimed that the City violated rights secured by the collective
bargaining agreement between the City and Professional Firefighters Association of Omaha, Local
385, and have been certified as a class representative in one of the following listed legal actions
currently pending before the District Court of Douglas County,Nebraska: Russell Matsunami and
Randall Hoke v. City of Omaha,Doc. 948,No.419;Michael D.Moran and John M. Johanek v. City
of Omaha,Doc. 948,No. 420; Donald L. Carrell and John P. Goessling v. City of Omaha,Doc. 948,
No. 422; Perry L. Guido, Douglas B. Lloyd, Richard D. Hiatte and Leslie Pennington v. City of
Omaha, Doc. 948,No. 423; Steven G. Freyer and Thomas J. Olig v. City of Omaha, Doc. 948,No.
424; Russell Matsunami and Randall J. Hoke v. City of Omaha, Doc. 959, No. 855; Michael D.
Moran and John M. Johanek v. City of Omaha, Doc 959,No. 856; Donald L. Carrell and John P.
Goessling v. City of Omaha, Doc. 959, No. 857; Perry L. Guido, Douglas B. Lloyd, Richard D.
Hiatte and Leslie Pennington v. City of Omaha,Doc. 959,No. 858;or Steven G. Freyer and Thomas
J. Olig v. City of Omaha, Doc. 959,No. 859 (herein collectively referred to as "the lawsuits"); and,
WHEREAS, a majority of the members of the respective classes represented in the lawsuits
are members of Professional Firefighters Association of Omaha,Local 385(hereinafter the"Union"),
an unincorporated labor association that is the collective bargaining representative for all sworn
employees of the City of Omaha Fire Department except the Chief and Assistant Chiefs of the
Department and represents such employees regarding wages,hours, and conditions of employment;
and,
WHEREAS, during the pendency of the lawsuits, the City and the Union have engaged in
collective bargaining of an agreement regarding the wages, hours, and conditions of employment
of the Union's members and, as representatives of the class members, have engaged in negotiating
matters at issue in the lawsuits; and,
WHEREAS, by reason of the disputes and controversies arising from the lawsuits and the
collective bargaining process, and in recognition and preservation of the interests of the parties in
the collective bargaining process,the parties hereto desire to compromise and settle all claims and
causes of action of any kind whatsoever which the respective class members have or may have in
the future arising out of or related to any alleged past failure or refusal on the part of the City to
comply with the call-back provisions of the collective bargaining agreement between the City and
Professional Firefighters Association of Omaha, Local 385, to and including the effective date for
a collective bargaining agreement between the City and the Union for 1998 through 2001.
v V
NOW,THEREFORE,for and in consideration of the mutual promises and agreements herein
contained, including the recitals above, and the monetary consideration to be exchanged, the parties
hereto agree as follows:
1. Within fifteen(15)days after approval of this Memorandum of Understanding by the
District Court of Douglas County,Nebraska, and upon the approval of the Omaha City Council, the
City shall, pursuant to Neb. Rev. Stat. section 25-901, make an offer to allow judgments to be
entered against it in the lawsuits in the cumulative amount of$1,350,000.00, plus pension and
Medicare contributions required of the City. Provided, however, that in no event shall the total
amount of the judgments exceed$1,572,750.00. The allocation of the lump-sum offer between the
respective lawsuits and the respective class members are set out in the Notice approved by the
District Court.
2. In their capacities as representatives of the respective classes, plaintiffs agree to
promote approval of this Memorandum of Understanding and acceptance of the offer by the
individual class members, support approval of this Memorandum of Understanding and acceptance
of the offer by the court,and accept the offer in a manner that complies with Nebraska Statutes. The
plaintiffs agree to seek acceptance of this Memorandum of Understanding from all class members.
The method of acceptance may include failure to file a written objection within a designated period
after receipt of notice being deemed acceptance.
3. Upon the District Court's approval of this Memorandum of Understanding and entry
of judgment,the amounts and manner of payments to the class members and attorneys fees shall be
made as follows:
a) The amount, if any, of the judgment proceeds allocated to each class member shall
be designated in the Notice approved by the District Court and in the judgment. Each class
member's entitlement shall be based on the number of calendar quarters during which the
member signed up for call back. The judgment proceeds designated for each member shall
be treated as retroactively paid wages. For retirement purposes,the designated amount shall
be allocated equally among the months in the quarters of 1996, 1997, or 1998 in which the
member signed up for call back. If a member's retirement from employment with the Omaha
Fire Department is approved by the Board of Trustees for the City of Omaha Police and Fire
Retirement System before the entry of judgment anticipated by this Memorandum of
Understanding, the member's allocated judgment proceeds shall be treated for retirement
purposes as being earned equally in each of the months during the quarters of 1996, 1997,
and 1998 in which the member had signed up for call back. The time the pension
contributions are paid shall not be determinative of when compensation was earned or
received by any member for purposes of calculating retirement benefits.
b) Within sixty (60) days after entry of the judgment, the City will pay to each class
member who has not perfected an appeal from the judgment one-half the amount designated
for the member in the judgment, less any withholding of income taxes and the member's
pension and Medicare contributions. This sum will be paid by city warrant or electronic fund
MEMORANDUM OF UNDERSTANDING - Page 2
transfer in the same manner as the class member's compensation or pension benefit is paid
by the City. The deductions for income taxes,pension, and Medicare will be determined by
the Omaha Finance Department and paid according to the applicable law to the applicable
agency.
c) On or before the regular City of Omaha employee payday falling closest to February
15, 1999,the City will pay to each class member who has not perfected an appeal from the
judgment the remaining one-half of the amount designated for the member in the judgment,
less any withholding of income taxes and the member's pension and Medicare contributions.
This sum will be paid by city warrant or electronic fund transfer in the same manner as the
class member's compensation or pension benefit is paid by the City. The deductions for
income taxes and Medicare will be determined by the Omaha Finance Department and paid
according to the applicable law to the applicable agency.
d) The City shall be permitted to withhold any amounts designated for payment to any
class member who perfects an appeal from the judgment.
e) Payment of the final portion of the judgment to the class member shall serve as
satisfaction of the judgment and the appropriate pleadings shall be filed. No interest shall
accrue on the judgment. The satisfaction shall apply to any and all claims, demands, or
causes of action of any kind whatsoever for back wages,unpaid straight time compensation,
unpaid overtime compensation, compensatory damages, liquidated damages, interest, costs,
attorney fees, or injunctive or declaratory relief which any member of the class represented
by plaintiffs have or might have, known or unknown, existing at the time the satisfaction is
filed which directly or indirectly relate to any past failure or refusal on the part of the City
to comply with the call-back provisions of the collective bargaining agreement between the
City and Professional Firefighters Association of Omaha, Local 385,up to and including the
effective date for a collective bargaining agreement between the City and the Union for 1998
and beyond.
4. Prior to entry of judgment, the individual actions filed as Doc. 959, No. 855; Doc
959, No. 856; Doc. 959,No. 857; Doc. 959,No. 858; and Doc. 959,No. 859 shall be certified as
class actions and consolidated with the individual actions indexed in Doc 948.
5. On July 7, 1998,the plaintiffs in Randy Hoke,Michael Moran,Donald Carrell,Perry
Guido, Steve Freyer, and Professional Firefighters Association of Omaha, Local 385 v. Hal Daub,
Doc. 971,No. 968 (Dist. Ct. of Douglas County)have dismissed that action.
6. This Memorandum of Understanding and any obligations stated herein is contingent
upon: (a) the lawsuits being certified by the court as class actions and execution of Memorandum
of Understanding by the certified class representatives of all litigation included in the lawsuits; (b)
approval by the Omaha City Council; and, (c) obtaining any necessary approval of the court. In the
event the conditions expressed in this paragraph are not met, or for any other reason this
Memorandum of Understanding is not completed,the terms and conditions of this Memorandum of
MEMORANDUM OF UNDERSTANDING - Page 3
.ry
Understanding shall not be directly or indirectly referred to by either party in any pleading, writing,
or hearing during the pendency of the lawsuits.
7. This Memorandum of Understanding contains the entire agreement between the
parties. It supersedes any and all prior agreements, arrangements, or understandings between the
parties on all subjects in any way related to the events or occurrences described in this Memorandum
of Understanding. No oral understandings, statements, promises, or inducements contrary to or
consistent with the terms of this Memorandum of Understanding exist. This Memorandum of
Understanding is not subject to any modification, waiver, or addition. Any changes in this
Memorandum of Understanding may be only by means of a writing signed by all parties and
approved by the Mayor of Omaha and a majority of the members of the Omaha City Council at the
time of the change.
8. It is expressly understood and agreed that the terms of this Memorandum of
Understanding are contractual and not merely recitals and that the agreements herein contained and
the consideration transferred is to compromise disputed claims, avoid litigation, and buy peace. At
no time will any representations, agreement, payments, or other consideration made or referred to
herein or as a result of this Memorandum of Understanding be construed as an admission of liability.
All liability is expressly denied.
9. All signatories to this Memorandum of Understanding warrant that they have read
it and fully understand its terms. They warrant that they are of legal age and legally competent and
authorized to execute this Memorandum of Understanding and that they do so of their own free will
and accord without reliance on any representation of any kind or character not expressly set forth
herein.
Qth
Dated this V day of July, 1998.
CITY OF OMAHA,NEBRASKA,
/ I
By:
aub, Mayor
PLAINTIFFS,
Russell Matsunami
:0144.4.&
Ran all Hoke
MEMORANDUM OF UNDERSTANDING - Page 4
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Michael D. Moran
7//1. Q6C PL a 14 I
Jo, M. Johanek
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Donald L Carrell
Perry L uido
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Douglas B. oyd
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Richard D. Hiatt%
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Leslie-'ennington '
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Steven G. Freyer
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Thomas J. ig
APPROVED AND AGREED:
I
John P. Fa homas O. Mumga d
ATTORN FOR PLA TIFFS / ATTORNEY FOR HE TY
j;(-,- �ofr.•,.._, -4( r ri41nej
/ MEMORANDUM OF UNDERSTANDING - Page 5
The Professional Firefighters Association of Omaha, Local 385 agrees to support the terms
of this Memorandum of Understanding and of the collective bargaining agreement between the City
and the Union for 1998 through 2001,without amendment,before the Omaha City Council and will
not support, financially or otherwise, any appeal from a judgment entered pursuant to this
Memorandum of Understanding. This Memorandum of Understanding and the collective bargaining
agreement shall be presented to the Omaha City Council for vote at the same Council meeting.
Professional Firefighters Association of Omaha, Local 385
hMl F. ell
President
MEMORANDUM OF UNDERSTANDING - Page 6
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