Fraternal Order of Police, Lodge No. 64 v. Personnel Board of Jefferson County

Summary

The court affirmed summary judgment for the County, Personnel Board, and sheriff, holding that the governing personnel rule gives appointing authorities discretion to suspend merit pay raises across the board. It also held that the enabling act's requirement for salary advancement based on efficiency and length of service does not prohibit that discretion because the act grants the Personnel Board broad authority over the civil-service pay system. The court rejected the employees' expressio unius argument because the statute did not prescribe an associated group or series of specific salary-advancement attributes.