Carroll v. Ringgold Education Ass'n

655 A.2d 613, 148 L.R.R.M. (BNA) 2820, 1995 Pa. Commw. LEXIS 109
CourtCommonwealth Court of Pennsylvania
DecidedFebruary 24, 1995
StatusPublished

This text of 655 A.2d 613 (Carroll v. Ringgold 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
Carroll v. Ringgold Education Ass'n, 655 A.2d 613, 148 L.R.R.M. (BNA) 2820, 1995 Pa. Commw. LEXIS 109 (Pa. Ct. App. 1995).

Opinions

KELLEY, Judge.

The Ringgold School District (District) and the Ringgold Board of School Directors (Board) appeal from a June 7, 1994 order of the Court of Common Pleas of Washington County (Chancellor) which ordered court-monitored bargaining between the Board and the Ringgold Education Association (Association).1 The Chancellor further ordered that all members of the Association and all nine Board directors were required to attend the negotiations.

The facts surrounding the District’s and the Board’s appeal to this court are as follows. The collective bargaining agreement between the District and the Association expired on August 31, 1993. Therefore, the 1993-94 school year began without a collective bargaining agreement.

The Association commenced a strike on February 9,1994 that ended upon the Association’s return to work on February 11, 1994. By agreement, the terms of the expired collective bargaining were extended. Negotiations occurred between the District and the Association including, the utilization of fact finding, mediation, and mandatory non-binding final best offer arbitration pursuant to Act 88.2 Despite the foregoing, the District and the Association did not successfully negotiate the terms of a new collective bargaining agreement. As a result, a second strike by the Association commenced on May 25, 1994.

Prior to the strike which began on May 25, 1994, the District provided 163 days of instruction to pupils attending schools in the District. On June 7,1994, in order to ensure that the District complied with the 180-day period of instruction mandated by the Public School Code of 1949,3 the Secretary of Education (Secretary) filed a complaint in equity and a petition for preliminary injunction with the Chancellor pursuant to section 1161-A of Act 88.4 The Secretary was seeking an injunction compelling the Association to return to work and the District to schedule the requisite number of school days in order to ensure that the pupils of the District would receive 180 days of instruction before June 30, 1994. Neither the District nor the Association filed a responsive pleading to the Secretary’s complaint in equity.

On June 7, 1994, simultaneously with the presentment of the Secretary’s petition for preliminary injunction, the Association presented to the Chancellor a motion for court-ordered negotiations. After argument on the [616]*616Secretary’s petition and the Association’s motion, the Chancellor granted the Secretary’s petition by order issued on June 7, 1994. This order granting the requested injunctive relief was not appealed to this court.

Immediately after granting the injunctive relief to the Secretary, the Chancellor issued a second order on June 7, 1994 which repeated, verbatim, the order granting the injunction, but with added language compelling the Board and the Association to engage in court-monitored bargaining commencing June 8, 1994 at 9:00 a.m. The second order further directed that all members of the Association and the nine directors of the Board were required to attend the negotiations.

On June 8, 1994, the District and the Board presented to the Chancellor an application for relief and for stay of order granting the Association’s motion for court-ordered negotiations without notice to the other parties. The Chancellor denied the application for relief and stay but directed that the Board directors with conflicts of interest were not to participate in the actual negotiations.

Thereafter, the District and the Board filed a notice of appeal to this court resulting in an automatic supersedeas of the Chancellor’s order pursuant to Pa.R.A.P. 1736. The Association presented to the Chancellor a motion to vacate the automatic supersedeas which was granted by the Chancellor by order dated June 17, 1994.5 By order dated June 21, 1994, this court granted the District’s and the Board’s request for reinstatement of the automatic supersedeas of the Chancellor’s June 7, 1994 order.

Initially, we note that there is no dispute that the only order on appeal before this court is that portion of the chancellor’s second order of June 7, 1994 ordering court-monitored negotiations between the Board and the Association.6 With respect to the District’s and the Board’s appeal from this order, it is clear that the appeal is now technically moot as the 1993-94 school year has ended and the District and the Association are now into the next school year for 1994-95.7 Yet, this appeal raises an issue of [617]*617important public interest, capable of repetition, which is apt to elude review. Therefore, we shall entertain this appeal with respect to the specific issue of whether the Chancellor had the authority to order court-monitored bargaining between the Board and the Association.8 See Jersey Shore; Reichley by Wall v. North Penn School District, 533 Pa. 519, 626 A.2d 123 (1993); Colonial Gardens Nursing Home v. Bachman, 473 Pa. 56, 373 A.2d 748 (1977).

It is important for this court to first summarize the pertinent provisions of Act 88. Act 88 provides for collective bargaining between public school entities and public school employees or employee organizations.9 Act 88 provides that collective bargaining is

the performance of the mutual obligation of the employer or his representative and the representative of the employes to meet at reasonable times and confer in good faith with respect to wages, hours and other terms and conditions of employment or the negotiation of an agreement or any question arising thereunder and the execution of a written contract incorporating any agreement reached, but such obligation does not compel either party to agree to a proposal or require the making of a concession.

24 P.S. § 11-1111-A.

If an impasse between the parties occurs during collective bargaining, Act 88 sets forth certain steps to be taken in order to facilitate the reaching of a mutually acceptable collective bargaining agreement. First, the dispute or impasse is submitted to mediation which shall continue for so long as the parties have not reached an agreement. 24 P.S. § 11-1121-A; 24 P.S. § 11-1122-A. If after 45 days, mediation does not result in an agreement, the next step is submission to a fact finding panel and, thereafter, to nonbinding final best offer arbitration. 24 P.S. § 11-1122-A; 24 P.S. § 11-1125-A.

During the collective bargaining process, the employees are permitted to strike following forty-eight hours notice to the school entity. 24 P.S. § 11-1101-A. If a strike by employees or a lockout by an employer will prevent the school entity from providing the mandated 180 days of instruction required by section 1501 of the Public School Code, the parties are required to submit to mandated final best offer arbitration. 24 P.S. § 11-1125-A. When an employee organization is on strike for an extended period that would not permit the school entity to provide the mandated 180 days of instruction, the Secretary may initiate appropriate injunctive proceedings providing for the required period of instruction. 24 P.S. § 11-1161-A.

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Related

Brown v. Board of Education
347 U.S. 483 (Supreme Court, 1954)
Reichley by Wall v. NORTH PENN SCH. D.
626 A.2d 123 (Supreme Court of Pennsylvania, 1993)
Jersey Shore Area School District v. Jersey Shore Education Ass'n
548 A.2d 1202 (Supreme Court of Pennsylvania, 1988)
Armstrong School District v. Armstrong Education Ass'n
595 A.2d 1139 (Supreme Court of Pennsylvania, 1991)
Colonial Gardens Nursing Home, Inc. v. Bachman
373 A.2d 748 (Supreme Court of Pennsylvania, 1977)
Butler County v. Pittsburgh, Harmony, Butler & New Castle Ry. Co.
148 A. 504 (Supreme Court of Pennsylvania, 1929)
Carroll v. Ringgold Education Ass'n
652 A.2d 417 (Commonwealth Court of Pennsylvania, 1994)
Advanced Management Research, Inc. v. Emanuel
266 A.2d 673 (Supreme Court of Pennsylvania, 1970)
Roth v. M'Clelland
6 Watts 68 (Supreme Court of Pennsylvania, 1837)

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Bluebook (online)
655 A.2d 613, 148 L.R.R.M. (BNA) 2820, 1995 Pa. Commw. LEXIS 109, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carroll-v-ringgold-education-assn-pacommwct-1995.