East Orange Educational Support Professionals' Association v. East Orange Board of Education

CourtNew Jersey Superior Court Appellate Division
DecidedFebruary 25, 2025
DocketA-3657-21
StatusUnpublished

This text of East Orange Educational Support Professionals' Association v. East Orange Board of Education (East Orange Educational Support Professionals' Association v. East Orange Board of Education) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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East Orange Educational Support Professionals' Association v. East Orange Board of Education, (N.J. Ct. App. 2025).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-3657-21

EAST ORANGE EDUCATIONAL SUPPORT PROFESSIONALS' ASSOCIATION and EAST ORANGE MAINTENANCE ASSOCIATION,

Plaintiffs-Respondents/ Cross-Appellants,

v.

EAST ORANGE BOARD OF EDUCATION,

Defendant-Appellant/ Cross-Respondent. _______________________________

Argued January 16, 2024 – Decided February 25, 2025

Before Judges Gilson and DeAlmeida.

On appeal from the Superior Court of New Jersey, Chancery Division, Essex County, Docket No. C-000053-22.

Ramon E. Rivera argued the cause for appellant/cross- respondent (Antonelli Kantor Rivera, PC, attorneys; Ramon E. Rivera, of counsel; Lawrence M. Teijido and Madelaine P. Hicks, on the briefs).

Sanford R. Oxfeld argued the cause for respondents/cross-appellants (Oxfeld Cohen, PC, attorneys; Sanford R. Oxfeld and William P. Hannan, of counsel and on the brief).

The opinion of the court was delivered by

DeALMEIDA, J.A.D.

Defendant East Orange Board of Education (Board) appeals from the June

16, 2022 order of the Chancery Division to the extent it confirms an arbitration

award of extra compensation to the Board's custodial employees who reported

to work when school facilities were closed to students during the COVID-19

state of emergency. The award was based on a contractual provision entitling

custodial employees to extra compensation when they work on days when

"schools are closed for an emergency."

We conclude the arbitration award of extra compensation to the Board's

custodial employees conflicts with the public policy embodied in N.J.S.A.

18A:7F-9(e)(1). That statute, enacted at the start of the COVID-19 state of

emergency, provides that when school facilities are closed for an extended

period due to a state of emergency, school employees shall be compensated "as

if the school facilities remained open for any purpose . . . ." As a result, we

A-3657-21 2 reverse the June 16, 2022 order to the extent it confirms the arbitration award of

extra compensation to custodial employees and remand for entry of an order

vacating that aspect of the arbitration award.

Plaintiffs East Orange Educational Support Professionals' Association

(SPA) and East Orange Maintenance Association (MA) (collectively the

Unions) cross-appeal from the June 16, 2022 order to the extent it confirms the

arbitration award denying extra compensation to the Board's maintenance

employees who reported to work during the COVID-19 state of emergency.

Because the Unions' complaint asked the trial court to confirm the arbitration

award in its entirety, the trial court declined to hear the Unions' challenge to the

portion of the arbitration award denying extra compensation to the Board's

maintenance employees. We agree with the trial court's conclusion that the

Unions did not raise a challenge to the arbitration award concerning maintenance

employees in the trial court. We therefore dismiss the cross-appeal.

I.

On March 9, 2020, the Governor declared a state of emergency concerning

the COVID-19 pandemic. Exec. Order No. 103 (Mar. 9, 2020). The COVID-

19 state of emergency ended on July 4, 2021. Exec. Order No. 244 (June 4,

2021).

A-3657-21 3 During the COVID-19 state of emergency, East Orange school facilities

were closed to students, with the exception of September and October 2020, and

two weeks in 2021. While school facilities were closed, students received

virtual instruction. However, other activities, including providing lunches to

students, continued to take place at school facilities. In addition, some Board

personnel, such as administrators and office staff, were periodically present at

school facilities. The Board's custodial, security, and maintenance employees

regularly reported in person to school facilities to work.

On April 14, 2020, the Governor enacted L. 2020, c. 27, parts of which

were later codified as amendments to N.J.S.A. 18A:7F-9. The statute provides

in relevant part:

Nothing in subsection b., c., or d. of this section [permitting virtual instruction of students] shall be construed to limit, supersede or preempt the rights, privileges, compensation, remedies, and procedures afforded to public school employees or a collective bargaining unit under federal or State law or any provision of a collective bargaining agreement entered into by a school district. In the event of the closure of the schools of a school district due to a declared state of emergency . . . for a period longer than three consecutive school days, public school employees covered by a collective negotiations agreement shall be entitled to compensation, benefits, and emoluments as provided in the collective negotiations agreement as if the school facilities remained open for any purpose and for any time lost as a result of school closures or use of

A-3657-21 4 virtual or remote instruction, except that additional compensation, benefits, and emoluments may be negotiated for additional work performed.

[N.J.S.A. 18A:7F-9(e)(1).]

SPA is the collective bargaining representative of the Board's custodial

employees. MA is the collective bargaining representative of the Board's

security and maintenance employees. At the times relevant to this appeal, the

three categories of employees were covered by separate collective bargaining

agreements (CBA) with the Board.

Article XXIII, Subsection B of the CBA for custodial employees provided

Emergency School Closings

1. Custodians who do not work on any day when schools are closed for an emergency shall not be paid and shall be docked an amount equal to one (1) day of pay.

2. Custodians who do work on any day when schools are closed for an emergency shall be paid 1 1/2 times their salary in addition to their regular day of pay.

Article XIII, "Emergency School Closing," of the CBA for security employees

provided:

The Board agrees to compensate all security personnel for their regular day[']s pay whenever schools are closed for reasons of emergency. A regular day is

A-3657-21 5 defined as the number of hours contained in a normal work day for the security staff member involved. All members of the Union required to work during a State of Emergency, as declared by the Governor, shall be compensated time and one-half.

Article VII, Section 9 of the CBA for maintenance employees provided in

relevant part:

....

c. Maintenance personnel who are on the roster and who work on any day when schools are closed for an emergency shall be paid 1.5 times their salary, in addition to their regular pay for the day.

k. The above provisions shall not apply on any day when the Governor of the State of New Jersey, or the Mayor of East Orange, or the Mayor of the Town in which the employee resides declares a "State of Emergency."

From March 13, 2020, to July 13, 2020, the Board paid its custodial,

security, and maintenance employees one-and-one-half times their regular pay,

in addition to their regular pay, for the time they worked while school facilities

A-3657-21 6 were closed to students. The Board did not change this practice when N.J.S.A.

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