Pennsylvania Labor Relations Board v. Michael A. Della Vecchia

The County of Allegheny appeals an Order of an en banc panel of the Commonwealth Court reversing an Order of the Court of Common Pleas of Allegheny County and reinstating the final Order of the Pennsylvania Labor Relations Board (PLRB). The PLRB found that an agreement entitled "Memorandum of Understanding", between the Allegheny County Recorder of Deeds and the Service Employees International Union (SEIU), Local 585, was a collective bargaining agreement under the terms of the Public Employe Relations Act (PERA), 43 P.S. § 1101.101 et seq. Inherent in that finding was a determination that the Recorder of Deeds was a "public employer" as that term is also defined under PERA, 43 P.S. § 1101.301(1) and under our decisions in Ellenbogen v. County of Allegheny, 479 Pa. 429, 388 A.2d 730 (1978) and Commonwealth ex rel. Bradley v. PLRB, 479 Pa. 440, 388 A.2d 736 (1978). For the reasons that follow, we reverse the Order of the Commonwealth Court.