Public Safety Employees Ass'n, Local 92 v. State

OPINION

COMPTON, Justice.

I. INTRODUCTION

This dispute arises out of arbitration proceedings between the State and the Public Safety Employees Association (PSEA). An arbitrator held that the State was obligated to pay certain employees geographic differential increases commencing September 1, 1990. The State maintained that it could not pay the differential increases by that date. It claimed that the Public Employment Relations Act (PERA), AS 23.40.070-23.40.260, required that the legislature appropriate the funds necessary to pay the increases. However, since the legislature was in recess and…