Alllegheny Intermediate Unit v. Allegheny Intermediate Unit Education Ass'n

590 A.2d 1348, 139 Pa. Commw. 453, 1991 Pa. Commw. LEXIS 243
CourtCommonwealth Court of Pennsylvania
DecidedMay 3, 1991
DocketNo. 351 C.D. 1990
StatusPublished

This text of 590 A.2d 1348 (Alllegheny Intermediate Unit v. Allegheny Intermediate Unit Education Ass'n) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Alllegheny Intermediate Unit v. Allegheny Intermediate Unit Education Ass'n, 590 A.2d 1348, 139 Pa. Commw. 453, 1991 Pa. Commw. LEXIS 243 (Pa. Ct. App. 1991).

Opinions

PELLEGRINI, Judge.

This is an appeal from the Court of Common Pleas of Allegheny County affirming an arbitration opinion and award between the Allegheny Intermediate Unit (School District) and the Allegheny Intermediate Unit Education Association (Union), involving a dispute that arose as a result of a staff realignment when the School District refused a teacher’s request to transfer to another program.

This dispute stems from a sequence of personnel moves known as “bumps” made as a result of the realignment of professional staff pursuant to the Section 54(c) of the collective bargaining agreement between the School District [455]*455and the Union.1 These moves began when Jeanne Kmetz-Donovic was bumped from her teaching position by another teacher with more seniority. Because Kmetz-Donovic, in addition to holding several teaching certificates, was certified as a school psychologist, she exercised her right to bump Krall, who bumped school psychologist Strommer, who bumped school psychologist Siegal. Siegal could not bump any other professional employee because he was only certified as a school psychologist and had less seniority than any other professional employee who-bumped into the school psychologist position.

The School District refused to allow Kmetz-Donovic’s bump, because allowing that bump would set forth the sequential bumps that could result in Siegsal being furloughed. In its written refusal, the School. District explained that if it allowed the request, additional realignments would have occurred, the ultimate result of which would be the furlough of Siegal, the least senior psychologist. The School District further explained that Siegal, who had eight years’ seniority as a psychologist, would have to be furloughed, because the only open positions were for [456]*456teachers and he had no teaching certificate. The School District stated that it could not furlough the psychologist because Section 1124 of the Public School Code of 1949 (School Code), Act of March 10, 1949, P.L. 30, as amended, 24 P.S. § 11-1124, dictates the only circumstances which would permit such action, and those circumstances did not exist. The School District offered Kmetz-Donovic her choice of teaching positions instead.

Kmetz-Donovic filed a grievance because she was denied the job of school psychologist. The parties were unable to reach an accord and the matter was referred to an arbitrator. In interpreting Section 54(c) of the collective bargaining agreement, the arbitrator found that nothing prohibits a teacher from bumping into a psychologist position, even if that bump ultimately results in the furloughing of an employee who has more seniority than other employees who are not being furloughed. The School District appealed the arbitrator’s decision to the trial court, which found that the arbitrator’s decision was drawn from the essence of the agreement and dismissed the School District’s appeal. The instant appeal followed.

Our scope of review in matters appealing an arbitrator’s decision is very limited. The arbitrator’s decision will not be overturned as long as it draws its essence from the collective bargaining agreement. Leechburg Area School District v. Dale, 492 Pa. 515, 424 A.2d 1309 (1981). This “essence test” has been explained by our Supreme Court as follows:

This so-called 'essence test’ draws its origins from federal decisional law which mandates judicial deference to an arbitrator’s findings.
‘It is the arbitrator’s construction which was bargained for, and so far as the arbitrator’s decision concerns the construction of the contract, the courts have no business overruling him because their interpretation of the contract is different from his.’ United Steelworkers v. Enterprise Wheel and Car Corp., 363 U.S. 593, 599, 80 S.Ct. 1358, 1362, 4 L.Ed.2d 1424 (1960).
[457]*457The essence test requires a determination as to whether the terms of the agreement encompass the subject matter of the dispute. Where it is determined that the subject matter of the dispute is encompassed within the terms of the agreement, the validity of the arbitrator’s interpretation is not a matter of concern to the court.

Id. 492 Pa. at 520-21, 424 A.2d at 1312-13.

The School District contends that the arbitrator’s decision is not derived from the essence of the collective bargaining agreement for several reasons. First, it contends that the arbitrator exceeded his authority by finding that Section 1125.1 of the School Code2 does not allow it to reject a personnel move if it deems it to be educationally unsound.

In Dallap v. Sharon School District, 524 Pa. 260, 571 A.2d 368 (1990), our Supreme Court, interpreting Section 1125.1, held that in a realignment caused by declining enrollment, school districts must replace less senior employees with more senior employees who carry proper certification. The Supreme Court then stated:

[458]*458[W]here circumstances admit of more than one possible realignment ... the district may consider the impact of each on the educational program to determine which is most sound, so long as within the chosen plan more senior employees are provided with the opportunity to fill positions for which they are certificated and which are being filled by less senior employees.

Id. 571 A.2d at 370.

The School District contends that it has a right to reject Kmetz-Donovic’s bump because such a personnel move would be educationally unsound and would result in less senior employees not being furloughed, both of which they contend are in violation of Section 1125.1 of the School Code.

Assuming the School District’s argument is valid that Section 1125.1 provides that a school district may consider the educational needs of the district when making staff realignments, and that moves had to be made so that less senior employees were furloughed, that argument does not apply in this case. Subsection (e) of Section 1125.1 authorizes that collective bargaining agreement to establish different criteria for staff realignments, including the school district’s right to reject a personnel move because it deems it to be educationally unsound. Section 1125.1(e) of the School Code, 24 P.S. § ll-1125.1(e). The arbitrator ruled that Section 54(c) of the collective bargaining agreement removed from the School District the right to reject a personnel move because it purportedly was educationally unsound. Because this interpretation by the arbitrator draws its essence from the agreement, we will not disturb it on appeal.

Next, the School District contends that the arbitrator’s decision fails to draw its essence from the collective bargaining agreement because it requires the School District to furlough an employee in contravention of Section 1124 of the Code. The School District argues that if Kmetz-Donovic is allowed to “bump” into a school psychologist position, this will lead to the furlough of Siegal, the most junior [459]*459psychologist.

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Related

United Steelworkers v. Enterprise Wheel & Car Corp.
363 U.S. 593 (Supreme Court, 1960)
Leechburg Area School District v. Dale
424 A.2d 1309 (Supreme Court of Pennsylvania, 1981)
Dallap v. Sharon City School District
571 A.2d 368 (Supreme Court of Pennsylvania, 1990)
Scranton Federation of Teachers, Local 1147 v. Scranton School District
444 A.2d 1144 (Supreme Court of Pennsylvania, 1982)
Hixson v. Greater Latrobe School District
421 A.2d 474 (Commonwealth Court of Pennsylvania, 1980)
McKeesport Area School District v. Cicogna
558 A.2d 116 (Commonwealth Court of Pennsylvania, 1989)

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Bluebook (online)
590 A.2d 1348, 139 Pa. Commw. 453, 1991 Pa. Commw. LEXIS 243, Counsel Stack Legal Research, https://law.counselstack.com/opinion/alllegheny-intermediate-unit-v-allegheny-intermediate-unit-education-assn-pacommwct-1991.