Ball-Chatham Community Unit School District No. 5 v. Illinois Educational Labor Relations Board

2022 IL App (4th) 210428-U
CourtAppellate Court of Illinois
DecidedOctober 6, 2022
Docket4-21-0428
StatusUnpublished

This text of 2022 IL App (4th) 210428-U (Ball-Chatham Community Unit School District No. 5 v. Illinois Educational Labor Relations Board) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ball-Chatham Community Unit School District No. 5 v. Illinois Educational Labor Relations Board, 2022 IL App (4th) 210428-U (Ill. Ct. App. 2022).

Opinion

NOTICE 2022 IL App (4th) 210428-U FILED This Order was filed under October 6, 2022 Supreme Court Rule 23 and is Carla Bender NO. 4-21-0428 not precedent except in the 4th District Appellate limited circumstances allowed Court, IL under Rule 23(e)(1). IN THE APPELLATE COURT

OF ILLINOIS

FOURTH DISTRICT

BALL-CHATHAM COMMUNITY UNIT SCHOOL ) Review of Order of the DISTRICT NO. 5, ) Illinois Educational Labor Petitioner, ) Relations Board v. ) THE STATE OF ILLINOIS EDUCATIONAL LABOR ) No. 20CA0005C RELATIONS BOARD; and BALL-CHATHAM ) EDUCATIONAL ASSOCIATION, IEA-NEA, ) Respondents. )

PRESIDING JUSTICE KNECHT delivered the judgment of the court. Justices Harris and Steigmann concurred in the judgment.

ORDER

¶1 Held: The appellate court affirmed, concluding the Board did not clearly err in finding the Association’s grievance was subject to arbitration.

¶2 Ball-Chatham Community Unit School District No. 5 (District) seeks direct review

of a decision of the Illinois Educational Labor Relations Board (Board) finding the District violated

section 14(a)(1) of the Illinois Educational Labor Relations Act (Act) (115 ILCS 5/14(a)(1) (West

2018)) when it refused to arbitrate a grievance brought by Ball-Chatham Educational Association,

IEA-NEA (Association). The District argues the Board’s decision should be reversed because the

Board clearly erred in finding the Association’s grievance was subject to arbitration. For the

reasons that follow, we disagree and affirm.

¶3 I. BACKGROUND

¶4 In 2015, the District, an educational employer, and the Association, an employee

organization that is the exclusive representative of a bargaining unit of the District’s employees, engaged in collective bargaining negotiations. During the negotiations, the Association, according

to a stipulation of facts, “raised initial salary placement for new hires as a bargaining issue,” to

which “[t]he District’s team responded that initial salary was a management prerogative, and one

they would not bargain.” The negotiations ultimately resulted in a three-year collective bargaining

agreement (Agreement), effective from August 2015 to August 2018.

¶5 The Agreement contains the following relevant provisions. Article I recognizes the

Association as the exclusive representative “for all regularly employed full-time and part-time

certified teachers, counselors, librarians, instructional coaches, instructional technology

coordinators, speech and language pathologists, social workers, psychologists, and certified school

nurses who are paid from the salary schedules attached hereto and made a part here of as Schedules

A-1, A-2, and A-3.” Schedules A-1, A-2, and A-3, although not part of the record, undisputedly

set forth salary schedules based, at least in part, on a staff member’s years of service/experience

(terms which have been used interchangeably by the parties) and level of education. Article X, in

turn, states: “Employees shall be paid in accordance with the salary schedules attached hereto and

made a part here of as Schedule A-1 (2015-2016), Schedule A-2 (2016-2017), and Schedule A-3

(2017-2018), each such employee shall move downward one vertical step for each successive year

of employment, in which the employee has worked 91+ days. Employees will also move

horizontally if applicable.” Article V provides: “The [A]ssociation President shall be notified via

email of all staffing changes within 7 business days, including newly hired teachers,

reassignments, resignations, retirements, and long-term subs. The notification shall include salary

schedule placement.” Finally, Article II sets forth a grievance procedure that culminates in binding

arbitration. It defines a “grievance” as “[a]ny claim by an employee or the Association that there

has been an alleged violation, misinterpretation or misapplication of the terms of this Agreement.”

-2- ¶6 On or before August 2017, the District’s superintendent recommended hiring

several individuals as teachers for the 2017-2018 school year at salaries the superintendent

negotiated with the teaching candidates. A number of the candidates agreed to a starting salary

“that, based upon their years of teaching in other school districts, was lower than would be paid to

a bargaining unit member with the same number of years of experience but with all years having

been spent in the District.” The District accepted the recommendations from its superintendent and

hired the candidates. The District did not give the Association the required notice of staff changes

set forth in Article V of the Agreement. Eventually, the Association learned of nine teachers who

were hired at the comparatively lower salaries.

¶7 In April 2018, the Association submitted a grievance. The Association alleged: “It

has come to the attention of the [Association] that teachers are being inappropriately placed on the

salary schedule commensurate with their years of experience and/or education.” The Association

asserted the District “violat[ed], misinterpret[ed], or misapply[ied] [the] terms and conditions of

the [A]greement” set forth in Article V, Schedule A-3, and Article I. The Association requested

the District place all members on the 2017-2018 salary schedule in accordance with their

experience and education, provide back compensation to all affected members, cease and desist

from violating the terms and conditions of the Agreement, and apply the Agreement consistently

and fairly to all members. Thereafter, the Association and the District engaged in mediation as part

of the grievance process. The mediation did not resolve the issues, and arbitration was scheduled

for April 2019.

¶8 In March 2019, the District informed the arbitrator of an issue of arbitrability. The

arbitrator directed the parties to provide written statements on the issue. As part of its written

statement, the District conceded it did not give the Association the required notice of staff changes

-3- set forth in Article V of the Agreement. Ultimately, the District took the position the grievance

was inarbitrable, and the Association took the position the grievance was arbitrable. The arbitrator

directed the parties to adhere to the scheduled arbitration, indicating the issue of arbitrability and

the merits of the grievance would be addressed at the arbitration. The District refused to proceed

with the arbitration as a method to challenge arbitrability.

¶9 In July 2019, the Association filed an unfair labor practice charge against the

District, alleging the District violated section 14(a)(1) of Act when it refused to arbitrate the

grievance brought by the Association. Both the Association and the District filed position

statements. The Executive Director of the Board, following an investigation, issued a complaint,

to which the District filed an answer. The Association and the District agreed, as indicated above,

to proceed on a stipulation of facts. The District submitted a brief on the stipulation, while the

Association elected to stand on its position statement.

¶ 10 With respect to the issue of arbitrability, the Association maintained the complaints

in its grievance about the District’s failure to give the required notice of staff changes and its failure

to appropriately place new hires on the salary schedule were subject to arbitration. The District

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2022 IL App (4th) 210428-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ball-chatham-community-unit-school-district-no-5-v-illinois-educational-illappct-2022.