## Facts

- A municipal labor-relations ordinance granted city employees collective-bargaining rights, conditioned on representation in an “appropriate unit” and prohibiting any unit that included both supervisory and nonsupervisory personnel.
- The ordinance defined certain employer conduct as unfair labor practices and directed unfair labor practice disputes to the State Mediation and Conciliation Service.
- The firefighters’ union historically represented a bargaining unit that included lieutenants and captains, reflecting the City’s prior recognition that those ranks were not supervisory.
- During 1993 negotiations for a successor collective bargaining agreement, the City asserted that lieutenants and captains were “supervisory personnel” and therefore could not lawfully remain in the unit; the union disputed the classification.
- The prior agreement (effective July 1, 1990–June 30, 1993) contained an impasse/mediation clause that deemed an impasse reached by May 1, 1993 if disputes remained and required submission of the dispute to mediation.
- The union filed suit seeking a preliminary injunction to stop the City from (1) taking the supervisory-status question to impasse and (2) unilaterally removing lieutenants and captains from the bargaining unit.
- The circuit court denied preliminary injunctive relief and dismissed the complaint; the union appealed.

## Issues

1. Whether the circuit court erred in denying a preliminary injunction that would bar the City from taking the supervisory-status dispute to impasse and then unilaterally excluding lieutenants and captains from the bargaining unit.
2. Whether the ordinance’s allocation of dispute-resolution authority (including unfair labor practice procedures and mediation mechanisms) made judicial injunctive intervention improper at this stage.

## Decision

- The appellate court affirmed the circuit court’s denial of a preliminary injunction and dismissal of the complaint.
- The court held that, on this record, injunctive relief was not warranted to prevent the City from proceeding to impasse and acting on its position regarding unit composition.
- The court emphasized that the ordinance supplied specialized processes for labor-relations disputes, counseling against substituting immediate equitable relief.
- The City’s historical treatment of lieutenants and captains as nonsupervisory did not, by itself, bar the City from asserting a different classification consistent with the ordinance’s unit-composition limits.

## Legal Principles

- When a municipal labor ordinance provides a designated process for resolving labor-relations disputes (including alleged unfair labor practices), courts generally avoid bypassing that scheme through preliminary injunctions absent a strong showing of necessity.
- A preliminary injunction is extraordinary relief and may be denied where the governing statutory/contractual framework provides mechanisms to address the dispute and the movant fails to establish the required equitable predicates (including likely success and irreparable harm).
- Disputes about whether positions are “supervisory” can function as representational/unit-composition questions under governing law, even when they arise during bargaining; courts may leave such disputes to the ordinance’s processes rather than freezing bargaining positions by court order.
- Past inclusion of positions in a bargaining unit does not necessarily estop a public employer from later asserting that the positions are supervisory under applicable unit-appropriateness rules.

## Conclusion

The court upheld the denial of preliminary injunctive relief and dismissal of the union’s suit, reasoning that the ordinance’s labor-dispute framework and the nature of the supervisory-status controversy did not justify court-ordered restraints on the City’s ability to proceed through bargaining, impasse, and related processes.


Annapolis Prof’l Firefighters Loc. 1926 v. City of Annapolis, 100 Md. App. 714, 642 A.2d 889 (Ct. Spec. App. 1994)