Department of Public Safety v. State Board of Labor Relations

Summary

The court reversed the trial court because it applied an improper legal standard when reviewing whether state police lieutenants and captains were managerial employees excluded from collective bargaining. The statutory term "principal functions" does not require employees to exercise independent judgment under the relevant criteria; instead, the functions must be the position's most important, consequential, or influential duties. The case was remanded for the labor board to reconsider the employees' status under that standard. Katz, J., dissenting, joined by Palmer, J., would have affirmed because the statute was ambiguous and the employees lacked the required independent judgment and policy-making participation.