MassCOP Supports Police Officers Serving in National Guard after Town of Rockport Refuses to Accept Arbitration Award

You may recall my August 8, 2016 blog post announcing an arbitrator’s award that granted back benefits to two full-time Rockport police officers who also serve in the National Guard. The Town had a practice of paying the officers their full salaries when they went to trainings on Cape Cod for several years when the interim police chief – on a complete misreading of the relevant statutes – concluded it was illegal to do this and began deducting their National Guard stipends from their pay. The local police union, supported by the Massachusetts Coalition of Police (MassCOP), fought the Town’s move; MassCOP assigned me (John M. Becker of Sandulli Grace, P.C.) to provide legal services to the officers and their local union.

The arbitrator ruled against the Town and ordered the officers to be paid as before. The decision even received some media attention – Michele McPhee discussed the case on her radio program. For a short time, it seemed as if Rockport was back on the right track.

According to the collective bargaining agreement between the Town and the Union, arbitrators awards are “final and binding”, but less than 30 days after the arbitrator’s award, the Town filed a petition in the state Superior Court asking a judge to overturn the decision because, it argued, the arbitrator had “exceeded his authority” and the award required the Town to violate the law.

Once again, MassCOP authorized Sandulli Grace to represent the local union – this time at the Superior Court. We recently filed a response to the Town’s appeal on behalf of the Rockport police union arguing that the appeal was frivolous and has no legal basis. We asked the Court to not only confirm the award but also require the Town to pay the Union’s legal fees in the frivolous appeal.

In this time of uncertainty and change, when so many misguided people here and abroad seek to solve problems through hatred and violence, we have to rely on the men and women who have chosen to serve in America’s volunteer military more than ever. The police officers in this case are full-time members of the Rockport police force and they have made significant sacrifices to serve in the National Guard. The Town of Rockport’s former practice of not deducting the National Guard stipends from their pay for attending mandatory trainings was the right thing to do. When the Town decided to cut officers’ pay for serving in the military, that was the wrong thing to do. Fortunately, the officers were part of a Union that had a collective bargaining agreement with the Town. That agreement gave them the right to challenge the Town’s change in practice before a neutral third-party arbitrator, who quickly realized that the Town’s position was wrong and no law prevented it from continuing to do the right thing.

It should have ended there. The Town should have accepted the “final and binding” ruling of the arbitrator and moved on. What possessed the Town and its labor counsel (from KP Law, formerly Kopelman & Paige, in Boston) to continue to expend time and money on depriving these hard-working officers of income? Is it simply about saving money? Because the amount they are saving by deducting the National Guard stipends is only a miniscule fraction of the Police Department budget. Is it a case of arrogance – they’re so sure they’re right that they won’t accept anyone telling them otherwise? I don’t have the answers. All I know is that these officers deserve better – their local union knows it, MassCOP knows it, and we at Sandulli Grace know it – and we will continue to fight on their behalf for as long as necessary.

Susan Horwitz to Receive Prestigious Labor Attorney Award at the Labor Guild’s Cushing-Gavin Awards Dinner on December 2, 2016

Susan Horwitz, a senior partner at Sandulli Grace, P.C., has been awarded the 2016 Cushing-Gavin Award for Union Attorneys, the highest honor bestowed upon members of the Massachusetts labor-management community. She will receive the award at the Labor Guild’s 50th Anniversary of the Cushing-Gavin Awards Dinner on December 2, 2016 at the Boston Park Plaza.

For 70 years, the Labor Guild has advanced the interests of workers and advocated better problem solving communication between representatives of labor and management throughout New England. In 1952, the Guild started offering classes to workers through its School of Industrial Relations, now located at 66 Brooks Drive in Braintree. In the late 1960’s, the Guild expanded its membership base by launching a tripartite labor relations awards program to recognize distinguished representatives of the labor, management and neutral/auxiliary communities. These awards are for excellence in labor-management relations “exemplifying moral integrity, professional competence and community concern.” For the past 50 years, select individuals who meet these high standards have been honored at the Guild’s Cushing-Gavin Awards Dinner.

Those familiar with Susan and her career can easily attest to how she exemplifies the required traits of a Cushing-Gavin Awardee. Before going to law school, she developed a foundation in labor relations by spending 5 years with the U.S. Labor Department in New York City. She then attended Northeastern School of Law when she began her work with Sandulli Grace as a coop, becoming its 4th attorney in 1984 and a partner in 1988. Sandulli Grace now has 13 attorneys and has always specialized in representing unions and employees exclusively.

Susan has been an exceptional advocate for the Boston Police Patrolmen’s Association (BPPA), the Massachusetts Coalition of Police (MCOP), the International Brotherhood of Electrical Workers (IBEW) Local 1228 in the broadcasting industry and numerous other local unions and their members across Massachusetts. She is held in high regard by all of the Sandulli Grace clients not just for her tireless work on their behalf, but also for her utmost passion in doing so.

The Cushing-Gavin Awards Dinner has grown to be the largest annual event in the Boston labor-management community. Please consider joining us in supporting the Labor Guild and honoring Susan Horwitz and the other Cushing-Gavin Awardees on December 2, 2016 at the Boston Park Plaza. It is also a chance to meet many old friends and establish new ones as we all strive to improve our working lives. (Further information regarding the Dinner and tickets can be found HERE)

First Amendment Does Not Protect Employee Who Is “Just Doing His Job”

The Massachusetts Appeals Court today reaffirmed that an employee does not have First Amendment protection for statements made as part of his job. New Worcester County Sheriff Louis Evangelidis fired Jude Cristo, who had been the Director of Payroll and Human Resources. Cristo challenged his termination, claiming that he was fired because he complained that employees’ were not doing their jobs because they were engaging in political campaigning during work hours. Cristo claimed that the First Amendment protected his complaints. The Court disagreed.

In granting Evangelidis summary judgment, the Court of Appeals found that Cristo’s speech did not constitute protected expression for First Amendment purposes. The Court of Appeals noted settled Supreme Court precedent that is used to determine when a public employee’s speech is protected. In reviewing speech, the court asks, in part, whether the employee is speaking in their capacity as a citizen regarding a matter of public concern. The Court of Appeals agreed that Cristo was clearly commenting on a matter of public concern because the complaints he made to his supervisor were related to the potential misconduct of sheriff’s office employees. This speech was strongly tied to a matter of public concern because it related to public employee’s campaigning during work hours instead of performing their actual duties and committing other potentially unlawful acts.

However, the Court nonetheless found the speech to be unprotected because Cristo’s comments were made pursuant to his official duties and he was not necessarily commenting as a private citizen. The Court found that Cristo’s complaints were all made in furtherance of fulfilling his duties as the director of payroll and human resources, as his duties included making sure that employees correctly reported their time and included making sure that other employees complied with their human resources responsibilities. Consequently, as Cristo was merely making statements pursuant to his official duties and was not speaking in his capacity as a private citizen, his speech was not entitled to First Amendment protection.

This case is a reminder that while a public employee “does not leave her constitutional rights at the door” when she goes to work, those rights are curtailed when it comes to the operation of her governmental employer.

You can read the decision here.

BOSTON POLICE PATROLMEN’S ASSOCIATION WINS BIG IN APPEALS COURT – SIX TERMINATED POLICE OFFICERS REINSTATED

COURT AFFIRMS CIVIL SERVICE COMMISSION FINDING THAT PSYCHEMEDICS’ HAIR DRUG TESTING USES BAD SCIENCE

The Massachusetts Appeals Court issued a decision on October 7, 2016 regarding the civil service appeals of 10 Boston police officers who were terminated solely because their hair tested positive for illegal drugs. All 10 officers in the appeal denied that they had used illegal drugs. In Thompson v. Civil Service Commission, No. 15-P-330 (Mass. App. Ct.), the Appeals Court affirmed the decision of the Massachusetts Civil Service Commission ordering six of the officers to be reinstated. After 18 days of hearing, the Commission ruled on February 28, 2013 that the hair testing protocol used by Psychemedics, Inc. was based on bad science and the Boston Police Department could not rely on a positive drug test alone to terminate a police officer. All 10 officers are members of the Boston Police Patrolmen’s Association (BPPA), which provided legal and financial support for these appeals. The BPPA represents the 1500 patrol officers of the Boston Police Department in collective bargaining over matters of wages, hours and working conditions.

Based on its initial finding that the hair test result alone was insufficient to terminate an officer for violating the Department’s rule against using illegal drugs, the Commission went on to consider other factors, such as the credibility of the officers’ denials that they used drugs, to determine whether the Department had just cause to terminate. Using this additional information, the Commission found that the Department had just cause to terminate four of the 10 officers. The Commission ordered the remaining six officers reinstated, but without full back pay. Representing the officers at the Commission at the request of the BPPA were attorneys Alan Shapiro and Jennifer Rubin, both partners at Sandulli Grace, P.C.

The City of Boston and Boston Police Department appealed the Commission’s decision on the six reinstatements to the Superior Court. The four terminated officers also appealed, and the six reinstated officers appealed the portion of the decision denying them full back pay. The Superior Court issued a decision on October 6, 2014 affirming the Commission’s decision in large part, but agreeing with the six reinstated officers that they were entitled to full back pay.

In the next round, the City and Department appealed to the Appeals Court on the issue of the six reinstatements, and the four terminated officers also appealed. The Appeals Court’s October 7, 2016 decision affirmed the Commission’s decision, but adopted the Superior Court’s ruling that the six reinstated officers were entitled to full back pay. Sandulli Grace attorneys Alan Shapiro and John M. Becker, at the request of the BPPA, represented the 10 officers in the appellate proceedings.

Either or both parties may file a petition for further appellate review to the Supreme Judicial Court within 14 days. Unlike the Appeals Court, which must review all the appeals filed with it, the SJC may select which cases to review. In practice, the SJC rejects approximately 9 out of every 10 applications for further appellate review it receives in civil cases.

The implications of this case are significant for any Union or Employer where hair testing, particularly hair testing by Psychemedics, is conducted. The Civil Service Commission was unequivocal in its conclusion that there are too many unanswered questions and questionable scientific assumptions in Psychemedics’ current hair testing protocol to allow an employer to fire an employee covered by just cause (either in a collective bargaining agreement or statute) on the basis of a hair test result alone.

Masscop Members In Rockport Win Back National Guard Pay Benefit – Arbitrator Rejects Town’s Argument That Payments Are Unlawful.

Arbitrator Richard Boulanger handed a significant victory to Local 154 (Rockport) of the Massachusetts Coalition of Police, AFL-CIO (“Union”) on August 3, 2016 when he sustained a grievance over pay cuts by the Town of Rockport (“Town”) for officers attending National Guard training. In doing so, Arbitrator Boulanger rejected the Town’s argument that it could not legally pay officers their full pay during National Guard training.

Two Rockport police officers who served in the National Guard and had been receiving full pay while attending mandatory military training were informed in January 2015 that the Town would now be deducting their National Guard military allowances from their pay, because, the Town claimed, to do otherwise would be illegal. The Union filed a grievance over the pay cut, which proceeded to a hearing before Arbitrator Boulanger. The Massachusetts Coalition of Police provided legal support by assigning Attorney John M. Becker, of Sandulli Grace, P.C., to represent Local 154 and the two grievants.

In his decision [which may be found HERE], Arbitrator Boulanger recognized that the Town had established a past practice of paying employees who were members of the National Guard their full pay while on leave attending mandatory training, without deducting the military allowance the employees received. The practice was encompassed by the strong maintenance of benefits provision in the collective bargaining agreement (“CBA”) between the Town and the Union, which protects any job benefit that (1) existed in the past and (2) has not been contractually modified, even if it is not mentioned in the CBA.

Boulanger rejected the Town’s argument that paying officers without deducting military allowances violated the law. Boulanger reviewed four statutes relating to military pay. First, the federal military leave law, USERRA, does not contain any provisions regarding pay during National Guard training, and so was irrelevant. Of three state statutes with some relevancy, none actually applied to this case, Arbitrator Boulanger concluded. G.L. c. 149, § 52a, which had previously provided for 17 days of military training leave to members of the reserves, which could be “paid or unpaid at the Town’s discretion”, was repealed in 2014 and was no longer good law. Chapter 137 of the Acts of 2003, a local option law that the Town had adopted, allows for paying regular base salary without loss of leave or seniority, but minus any military pay or allowance, for officers in “active service.” But as Arbitrator Boulanger pointed out, the statute is inapplicable because the officers in this case were not in “active service” and National Guard training is specifically excluded from the scope of the law. The Town had not adopted G.L. c. 33, § 59, a local option law, but Arbitrator Boulanger found that statute to be the most relevant. If adopted, the law (as amended in 2014) requires municipalities to give employees in the armed forces full pay without deducting for military stipends or pay during training, for up to 34 days in a state fiscal year or 17 days in a federal fiscal year, without loss of seniority or accrued leave. Boulanger pointed out that, although the Town had not adopted G.L. c. 33, § 59, it had adopted Chapter 137 of the Acts of 2003, which provides that it “shall not limit or reduce a person’s entitlement to benefits under [G.L. c. 33, § 59].”

Ultimately, Arbitrator Boulanger concluded that, while no statute specifically authorized the Town to pay full pay to employees during National Guard training, no statute prohibited the payments either, so the past practice of the Town – which was fully consistent with the local option law, G.L. c. 33, § 59 – was lawful and enforceable. For these reasons, the Arbitrator sustained the grievance and ordered the Town of Rockport to pay the police officers full pay during military training without deducting military allowances going forward and pay the officer back pay to make them whole from the time their pay was cut in January 2015.

Appeals Court Upholds Power of Arbitrators to Decide Whether a Teacher has Professional Teacher Status

Today, the Appeals Court issued a decision holding that arbitrators, acting pursuant to their authority under G.L. c. 71, § 42, have the authority to determine if a dismissed teacher held professional teacher status at the time of his/her dismissal. Under G.L. c. 71, § 42, teachers who have three consecutive years of service with a school district are entitled to professional teacher status, which confers upon them certain procedural and substantive rights, including the right to challenge their dismissals before an arbitrator under a just cause standard.

The case, Plymouth Public Schools vs. Education Association of Plymouth, involved a special education teacher, who worked for the school district for five years. During those five years, the teacher took maternity leave twice, under the Family Medical Leave Act (“FMLA”). At the end of her fifth year, the school district notified her of its decision not to renew her for the upcoming year. The district believed that the teacher had not obtained professional teacher status because her service was interrupted by the two periods of maternity leave. The teacher and the union took the position that she had acquired professional teacher status by virtue of her five years as an employee of the school district. Accordingly, the union petitioned the Commissioner of Elementary and Secondary Education for arbitration. The Commissioner forwarded the petition to the American Arbitration Association for an arbitration to determine first, whether the teacher had professional teacher status, and, if she did, whether or not the district had just cause to terminate her employment.

The district filed suit in Superior Court. There, the district argued that the teacher did not have professional teacher status, that she had no right to arbitrate her dismissal, and that the question of whether or not she had professional teacher status could only be answered by the courts, rather than by an arbitrator. After the Superior Court ruled in the district’s favor, the teacher and the union appealed to the Appeals Court. The Appeals Court reversed the Superior Court’s decision and declined to decide whether or not the teacher had professional teacher status. In doing so, the Court ruled that the question of whether or not she had professional teacher status was one appropriately answered by an arbitrator, rather than the courts. As a result, the dismissal will be reviewed by an arbitrator who will have the power to determine whether the teacher had professional teacher status and, if so, whether she was dismissed for just cause. Had the court not decided in the union’s favor, teachers in a similar position would have to file suit in court to determine their professional teacher status, and then, if the court ruled in their favor, proceed to arbitration to obtain a determination on the merits of their dismissal. This decision reaffirms the Legislature’s intent to have arbitrators decide issues relating to the termination of teachers and avoids forcing teachers into costly, duplicative litigation.

The case was successfully litigated by Atty. Matthew Jones of the Legal Services division of the Massachusetts Teachers Association.

Here is a link to the decision.

Public Records Law Overhauled For First Time In 43 Years

The state’s public records law was updated today for the first time in 43 years. The new law, “An Act to Improve Public Records,” puts pressure on municipalities and agencies to respond quickly and adequately to public record requests by establishing strict timeline requirements and allowing for significant judicial measures in the event of noncompliance.

Most notably, the law allows judges to award attorney fees and costs, as well as punitive damages up to $5,000 for a lack of good faith, to requesters who succeed in court against an agency or municipality that fails to produce records according to the statute. This change accompanies a new timeframe for responding to requests. Like the current law, the new law requires a response within 10 business days. However, the new law will require a municipality or agency, if it cannot produce the requested records, to identify a reasonable timeframe for turning them over. That timeframe cannot exceed 15 days for an agency and 25 days for a municipality following the initial receipt of the request, unless otherwise agreed to by the requestor.

Additional provisions call for the use of electronic and digital transmission of records when possible (preferably in ‘searchable’ form), the designation of one or more employees as ‘records access officers,’ and the creation of a Public Records Assistance Fund. Further, agencies must host websites providing records of proceedings, annual reports, winning bids for public contracts, grant awards, agency budgets, minutes of open meetings, and more.

The law specifically clarifies that personal information of law enforcement and public safety personnel, including their home address, personal email address, and home telephone number, “shall not be public records” and “shall not be disclosed,” with limited exceptions that include requests made by public employee organizations such as unions. Section 10B. Similar personal information relating to family members of law enforcement and public safety personnel are explicitly not public records and should never be disclosed, without exception. Id.

The bill, House No. H.4333, passed unanimously in both the House and Senate on Wednesday and signed today by the governor, after being formed as a result of a compromise between two bills originating separately in each chamber. Most of the provisions of the new law take effect on January 1, 2017.

Court of Appeals for the Second Circuit Reverses District Court’s “Deflategate” Decision, Reinstates Brady’s Suspension

By a 2-1 decision, a panel of three judges of the Court of Appeals for the Second Circuit overturned District Court Judge Richard Berman’s decision that overturned the NFL’s suspension of New England Patriots’ quarterback Tom Brady.

In its decision, the majority held that Judge Berman ignored the exceptional deference federal law afford decisions of labor arbitrators and acted beyond the narrow scope of review federal courts are required to adhere to. Specifically, the Court held that in suspending Brady, NFL Commissioner Roger Goodell properly exercised the broad discretion given to him by Article 46 of the collective bargaining agreement to suspend players for “conduct detrimental” to the NFL and/or the integrity of the game.

In its decision, the Court highlighted and rejected each of the three bases upon which Judge Berman overturned Brady’s suspension: 1) that Brady was not given proper notice that his actions could result in a four-game suspension, 2) that testimony excluded from the arbitration made the decision fundamentally unfair, and 3) that the NFL’s denial of access to the investigative notes from the NFL’s General Counsel also amounted to fundamental unfairness. In the case of each, the Court ruled that Judge Berman acted beyond his authority and did not afford Goodell’s decision the deference it was entitled to under the federal Labor Management Relations Act and the Federal Arbitration Act. The Court noted that under federal law, so long as the arbitrator is “even arguably construing or applying the contract and acting within the scope of his authority” the decision must be upheld, and that a judge cannot simply substitute his judgment for that of the arbitrator.

It is worth noting that the point of controversy which received a large bulk of the media attention in this case, that Goodell was able to serve as arbitrator in a dispute involving discipline he himself meted out, was a relatively minor issue to the Court. The Court that found this arrangement is extremely unusual, but noted that it was the process explicitly called for by the collective bargaining agreement. This is consistent with a long line of cases emphasizing that when parties to a collective bargaining agreement agree to a grievance process which ends in final and binding arbitration, that the decision of an arbitrator should be just that: final, binding, and free from interference by the courts. It seems that if the NFL and the NFL Players Association are to fix what many agree is a broken system of disciplinary appeals, they will have to do so at the bargaining table, rather than in a courthouse.

What People Say When They Get Arrested

The Boston Globe has a front page story on April 10 titled “Arresting Words.” Written by columnist Yvonne Abraham, the story weaves the words from Boston police reports into a tapestry of what police officers face daily on the streets and in the health clinics and within the homes of people to whom they are called to respond. Most are poor, many suffer from mental or physical illness, some are violent or threaten violence.

We see and hear a lot about victims of police abuse. This story gives some small bit of insight into the world into which society sends its police officers. Perhaps because it thrives on sensationalism, the press usually fails to convey a true picture of the milieu in which police officers work. Police must at once be legal experts and social workers. Split second decisions are parsed by appellate judges and clinical psychologists years later, but only after they have spent weeks, months, and years poring over enormous amounts of data, much of which the officer on the scene had no knowledge of in the moment.

And how does society value the men and women in police work? It compensates them like other public employees – fire fighters, teachers, sanitation workers – but nowhere near the level of the judges or bureaucrats who sit in judgment over therm.

One would think that having an educated police force would be a good idea. In fact, in 1967, the President’s Commission on Law Enforcement and Criminal Justice (the Johnson Crime Commission) recommended more education for police officers. Massachusetts responded in 1970 by passing the Quinn Bill, now known as the Police Career Incentive Pay Program, codified as Mass. Gen. Laws Chapter 149, Section 108L. A local option law, it provided additional compensation ranging from 10% to 20% to 25% for an Associates’, Bachelor’s, and Masters/JD degree. When many municipalities accepted the program, thousands of police officers seized the incentive to gain college degrees. But the program’s Achilles heel was that, although its cost was supposed to be split between the state and the community, starting in the late 1980’s and continuing to the present day, the Legislature has underfunded the program to the point that it makes virtually no contribution to its one-half share.

In Boston, where one would think educated police officers would be a priority, the Boston Police Patrolmen’s Association and the City had negotiated for this benefit in 1998. But when the Commonwealth underfunded the program in 2009, the City simply shortchanged its educated police officers, reducing their salaries by thousands of dollars. The Supreme Judicial Court, which has no problem opining on the lofty standards to which police are held (“it is extremely important for the police to gain and preserve public trust, maintain public confidence, and avoid an abuse of power by law enforcement officials.” 1 ) voted unanimously to uphold these pay cuts for educated police officers.

The current solution to address police abuse is to put body cameras on police officers. If and when that happens, and if people actually watch 99+% of what the police see, they will perhaps gain some insight into the world into which this Globe article peers. As one veteran officer remarked to me, people would be horrified to actually have to look at some of what police see on a daily basis. He mentioned entering a house where multiple people and domestic animals had relieved themselves everywhere, creating a visual and olfactory experience that could only induce nausea.

The social and economic conditions depicted in this column were not created by the police. But it is the police who must spend much of their working lives dealing with them. As Jesse Jackson has written,

The president has created a Task Force on 21st Century Policy, with instructions to report in 90 days. He’s committed millions to put cameras on police. But he might be better advised to put cameras on bankers.

By putting this article on its front page, the Globe perhaps opened a few readers’ eyes. But there is much more that must be done

1 City of Boston v. Boston Police Patrolmen’s Ass’n, 443 Mass. 813 (2005)

SJC Determines That State Pension Forfeiture Statute Is A Fine, Subject To The Eighth Amendment

The Supreme Judicial Court has ruled that G.L. c. 32, § 15(4) is a fine and therefore subject to the restrictions of the Eighth Amendment of the United States’ Constitution. Section 15(4) provides for the forfeiture of a public employee’s pension and health insurance benefits if he/she is convicted of a crime relating to his/her position. The Court’s decision means that individuals convicted of minor crimes may not be subject to a complete forfeiture of their pension and retiree health insurance.

The case, Public Employee Retirement Administration Commission v. Bettencourt, involved, a lieutenant and twenty-five year veteran of the Peabody Police Department, who was convicted of twenty-one counts of unauthorized access of a computer system. Shortly after his conviction (which has since been appealed), the lieutenant applied for a superannuation retirement. However, as a result of the conviction, the Public Employee Retirement Administration Commission (“PERAC”) denied his application on the grounds that his retirement benefits and continuing health insurance were forfeited under G.L. c. 32, § 15(4). The issue before the Court was whether Section 15(4), as applied to this officer’s case, was an excessive fine under the Eight Amendment of the United States’ Constitution.

In determining that the forfeiture was an excessive fine, the Court held that Bettencourt had a property interest in his retirement benefits, that the forfeiture was a punishment (and hence, a fine), and that the fine as applied to him was disproportionate to the harm caused by the crimes for which he was convicted. As a result, the Court ruled that Section 15(4)’s forfeiture would not apply to Bettencourt’s pension and health insurance, allowing him to receive both in their entirety. Rather than determine what a non-excessive fine would be in this case, the Court deferred to the Legislature to determine how cases such as Bettencourt’s would be handled after forfeiture is deemed to be excessive.

This case is an important one, as the Court held for the first time that forfeiture under G.L. c. 32, § 15(4) is a fine subject to the restrictions of the Eighth Amendment. While the case did not strike down Section 15(4), unless and until the Legislature answers the Court’s call to create a remedy for individuals who have been excessively fined under Section 15(4), excessive forfeitures should result in an employee receiving the entirety of their retirement and health insurances benefits.

You can find the case details here.

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