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March 8, 2012

Yesterday the Supreme Judicial Court ("SJC") issued its much anticipated Quinn Bill decision in Adams v. City of Boston, which involved suit between the City and its police unions over the level of funding required by the City under its police labor contracts.  In a significant victory for municipalities, the SJC ruled in favor of the City, holding that it was only liable for its fifty percent share of Quinn Bill payments, G.L. c. 41, 108L, plus any amount the Commonwealth appropriated.


The key issue in the case was the enforceability of language in the collective bargaining agreements providing that if the Commonwealth failed to reimburse the City for its half of Quinn Bill payments, the City would only be obligated to pay its share plus the amount the Commonwealth provided.  The unions argued the Quinn Bill required municipalities to pay the full amount regardless of the Commonwealth's reimbursement because Quinn payments could not be limited by the terms of a collective bargaining agreement.


The SJC reasoned that the Quinn Bill was intended to require equal contribution from the municipality and the Commonwealth.  From this point, the SJC concluded that municipalities are only obligated to pay half of the cost of Quinn Bill payments plus the amount funded by the Commonwealth.  Accordingly, the limiting language in the City's collective bargaining agreements did not conflict with the Quinn Bill or Chapter 150E, the Commonwealth's public sector collective bargaining law, and is, therefore, enforceable.


Although municipalities that have accepted the Quinn Bill are not legally required to pay more than fifty percent, the SJC noted municipalities may do so by agreement.


Since the SJC's decision is based on the specific language contained in the City's collective bargaining agreements, other municipalities should be cautious in applying this decision without further analysis of the language in their own labor contracts.  Further, it is unclear what implication this case has for collective bargaining agreements that are silent on the obligation to pay where the Commonwealth does not fully fund its share.  As a result, we recommend all municipalities confer with their labor counsel regarding the impact of this decision on their Quinn Bill obligations.

Municipal Law Group

Mirick O'Connell

100 Front Street

Worcester, MA  01608

t 508.791.8500

f 508.791.8502


1800 West Park Drive, Suite 400

Westborough, MA  01581

t 508.898.1501

f 508.898.1502


Mirick O'Connell is a full-service law firm with offices in Worcester, Westborough and Boston, Massachusetts.  The Firm's principal practice groups include Business; Creditors' Rights, Bankruptcy and Reorganization; Elder Law; Family Law and Divorce; Intellectual Property; Labor, Employment and Employee Benefits; Land Use and Environmental Law; Litigation; Personal Injury; Public and Municipal Law; and Trusts and Estates.

This client alert is intended to inform you of developments in the law and to provide information of general interest.  It is not intended to constitute legal advice regarding a client's specific legal issues and should not be relied upon as such.  This client alert may be considered advertising under the rules of the Massachusetts Supreme Judicial Court.