City of Boston, Boston Public Library v. Professional Staff Ass'n

807 N.E.2d 229, 61 Mass. App. Ct. 105, 175 L.R.R.M. (BNA) 3004, 2004 Mass. App. LEXIS 466
CourtMassachusetts Appeals Court
DecidedMay 3, 2004
DocketNo. 02-P-1378
StatusPublished
Cited by5 cases

This text of 807 N.E.2d 229 (City of Boston, Boston Public Library v. Professional Staff Ass'n) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
City of Boston, Boston Public Library v. Professional Staff Ass'n, 807 N.E.2d 229, 61 Mass. App. Ct. 105, 175 L.R.R.M. (BNA) 3004, 2004 Mass. App. LEXIS 466 (Mass. Ct. App. 2004).

Opinion

Kaplan, J.

Summary. An arbitrator’s award revoked the ap[106]*106pointment of a library assistant to the position of professional children’s librarian on the ground that this candidate lacked the MLS (Master of Library Science) degree, a requirement, the arbitrator held, under the collective bargaining agreement. The Boston Public Library (BPL) brought the present action in Superior Court to vacate the award; the professional staff association (association) counterclaimed to confirm it. Upon the defendant’s motion for judgment on the pleadings, the judge disapproved the award so far as it held the MLS degree was required, relying for this opinion, as he said, on “unambigupus” language of the collective bargaining agreement. The judge, however, approved the revocation of the appointment because of irregularities in the procedure and manner of the appointment also noted by the arbitrator. We disagree with the judge and hold, in agreement with the arbitrator, that possession of an MLS degree is required. We agree with the judge and the arbitrator about the irregularities in the appointment. (An issue of the “reposting” of the vacancy also arises.)

The case. The BPL, on June 26, 2000, posted an opening for a permanent position as a professional children’s librarian, grade P2, at the Mattapan branch library. Ms. Tammy Coney, a professional children’s librarian, grade PI, serving at the Grove Hall branch library and having the academic qualifications of B.A. and MLS degrees, applied for the Mattapan position. She was interviewed by Ms. Karen Duff, coordinator of children’s and young adult- library services, and Ms. Cynthia Dromgoole, then recently appointed Mattapan branch librarian after service at the Brookline branch library. Coney was rejected in August, 2000. The reason given was that she did not have the desired supervisory ability based on management experience.

Ms. JoAnn Henry, a library assistant, also applied for the Mattapan position. She had served as library assistant for many years and in her service at Brookline had been a colleague of Dromgoole. Henry, was interviewed by Duff and Dromgoole and on September 28, 2000, was hired to assume the position at Mattapan, now downgraded to PI. At the time, Henry was working toward, but had not achieved, a B.A. degree, and of course did not possess an MLS degree.

The Henry hiring came promptly to the attention of Ms. Ellen [107]*107Graf, president of the association, and she expressed outrage at the breach of the rule, as she understood it, that a professional librarian must have qualified by attaining an MLS degree.

Coney, who had been rejected for Mattapan in August, 2000, was transferred to the Codman Square branch library in September, 2000, as a professional children’s librarian P1, and was then promoted to the P2 level in late October, about three weeks after the Henry hiring. Henry is taken to have commenced work at Mattapan on October 10, 2000.

Between September 28 and October 10 representatives of the association and the BPL conferred but nothing came of the discussions, and on October 23, 2000, the association filed a grievance against the Henry hiring. After exhaustion of grievance procedure, the matter reached the stage of arbitration.

The issue framed for arbitration was:

“Did the City of Boston violate the collective bargaining agreement by appointing JoAnn Henry to the position of Children’s Librarian (P1) at the Mattapan Branch Library? If so, what shall be the remedy?”

The arbitrator heard the parties at considerable length. As noted, he answered the first question yes on the ground that Henry did not possess an MLS degree. In the present action to vacate or confirm the award, the judge answered the question yes on the ground of the irregular manner of the appointment, but disapproved the MLS ground. We examine these grounds.

Requirement of MLS Degree1

Arbitrator’s position. The arbitrator held the Henry hiring to be in violation of the collective bargaining agreement as Henry did not satisfy the academic requirement of an MLS degree, and was not enrolled in the BPL’s “Pre-Professional” program (see Appendix).

1. By Article I, the agreement covers employees in both the [108]*108pre-professional and the professional services. Then comes Article VI (“Employment Status”), which in section 2 (“Permanent Employment”) (text in Appendix) describes how a pre-professional may become a professional P1. It is a condition of advancement to the latter status that the pre-professional shall have the MLS degree. Paragraph (B) of section 2 makes the point with particular clarity where it provides that a preprofessional may be tentatively selected to a professional PI position when in attendance at library school during the three-month period preceding his or her completion of the MLS degree. If the degree is earned as expected the PI appointment becomes permanent; but if the pre-professional fails to complete the degree in the three months, the opportunity is lost, though the BPL may consider “extenuating circumstances” and grant a reasonable period of grace for completion of the degree.2

2. The arbitrator answered a possible contention drawn from the job description for professional children’s librarian (P2) (Appendix) that the MLS degree is not crucial and other experience may be accepted as a substitute.

The minimum qualifications mentioned in the job description are the B.A. and MLS degrees. Then follows in the same paragraph: “In exceptional instances, specialized education, training and/or experience may be substituted for part or all of the educational requirements.” (The second paragraph refers to “ability to do the work,” a separate consideration.)

The arbitrator on the record made by the association accepted that the term “specialized education” appearing in the quoted minimum qualifications refers to “Ph.D. degrees and unique skills such as those possessed by individuals having Ph.D. degrees.” Thus Karon Shaft qualified with a Ph.D. in art history [109]*109and Stuart Walker in conservation. The association asserted, referring to a thirty-year period, that, apart from the “exceptional instances” in the sense of the art history and conservation cases, there was no case of the appointment of a person as a professional librarian who did not possess the MLS degree. According to the arbitrator, Duff herself “testified that all professional librarians have a bachelor’s degree, an MLS degree or an advanced degree in an area of specialty pertinent to professional library work.”

The arbitrator went on to assume, for argument’s sake, contrary to the foregoing reading of the job description, that “exceptional instances” had a broader scope of meaning. Even on that assumption he found the appointment of Henry could not be supported. Without derogating from Henry’s services as a library assistant, there was no showing of capacities sufficient to excuse compliance with the usual academic requirement of the MLS degree. Nor was there a showing of inability on the BPL’s part to find candidates who could qualify academically. Such difficulties in filling vacancies as had been encountered in the past were due, at least in part, to the BPL’s own lethargy in recruitment efforts. Indeed, Mr. David Young, director of human resources, conceded that one of his goals in assuming his new post was to strengthen those efforts.

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Bluebook (online)
807 N.E.2d 229, 61 Mass. App. Ct. 105, 175 L.R.R.M. (BNA) 3004, 2004 Mass. App. LEXIS 466, Counsel Stack Legal Research, https://law.counselstack.com/opinion/city-of-boston-boston-public-library-v-professional-staff-assn-massappct-2004.