State of Alaska, Appellant v. Public Safety Employees Association, Appellee

Summary

The court affirmed the superior court's decision upholding an arbitrator's reinstatement of an Alaska state trooper discharged for dishonesty. It recognized a public-policy exception to enforcing labor arbitration awards but held that the State failed to show an explicit, well-defined, and dominant Alaska public policy requiring termination or barring reinstatement for the trooper's relatively minor dishonesty. The court also held that the arbitrator did not commit gross error in finding no just cause for discharge because the arbitrator reasonably applied a disparate-treatment analysis and the State had previously treated comparable misconduct more leniently.