Other facts will be stated in the Discussion section as needed. C. Sick Leave . Funeral Leave . The Union argues that under the past practice, the word incorporates a spouse's grandfather. The death of a grandfather qualifies for one paid leave day.
Nothing is said about the spouse's grandfather.
Based upon the specificity and precision with which the parties drafted the language regarding parents, siblings and children, it must be assumed that the parties used the same drafting ability in allocating paid leave days for the death of a grandparent. Therefore, it must be inferred that nothing is said about a spouse's grandfather because the parties have not agreed to grant paid leave in that situation. Even if the language was ambiguous, the Union has not shown the presence of a binding past practice in this case. Witness Scott Sharp testified that five years ago he received paid leave for the funeral of his spouse's grandmother and that the City knew it was for his spouse's grandmother. Witness Lee Schmidt testified that ten years ago he was given paid leave to attend his spouse's grandparent's funeral, but he could not testify as to whether he specified to the City that it was his spouse's, and not his, grandparent.