In the Matter of Rutgers and International Brotherhood of Teamsters Local 97

New Jersey Superior Court Appellate Division·Decided June 24, 2026·No. A-2430-24·Unpublished

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NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ."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-2430-24

IN THE MATTER OF RUTGERS, THE STATE UNIVERSITY OF NEW JERSEY,

Petitioner-Appellant, and

INTERNATIONAL BROTHERHOOD OF TEAMSTERS LOCAL 97,

Respondent-Respondent.

PUBLIC EMPLOYMENT RELATIONS COMMISSION,

Respondent.

Argued April 28, 2026 – Decided June 24, 2026 Before Judges Gilson and Firko.

On appeal from the New Jersey Public Employment Relations Commission, PERC No. 2025-009.

James P. Lidon argued the cause for appellant (McElroy Deutsch Mulvaney & Carpenter LLP, attorneys; John J.

Peirano, of counsel and on the briefs; James P. Lidon, on the briefs).

James M. Mets argued the cause for respondent International Brotherhood of Teamsters Local 97 (Mets Schiro & Manetta, LLP, attorneys; James M. Mets, of counsel and on the brief; Brian J. Manetta and Joanna Sowa, on the brief).

Frank C. Kanther, Deputy General Counsel, argued the cause for respondent Public Employment Relations Commission (Christine Lucarelli-Carneiro, General Counsel, attorney; Frank C. Kanther, of counsel and on the brief).

PER CURIAM Rutgers, the State University of New Jersey (Rutgers) appeals from a February 27, 2025 final agency decision by the Public Employment Relations Commission (Commission), which denied Rutgers' scope of negotiation petition seeking to restrain binding arbitration of a grievance. Discerning no error of law and nothing arbitrary, capricious, or unreasonable in the Commission's decision, we affirm.

I.

Rutgers is an instrumentality of the State of New Jersey and operates the State University, as well as various health care facilities. In 2017, Rutgers adopted an Immunization Policy requiring vaccination for certain A-2430-24

communicable diseases, including influenza (the Vaccine Policy). The Vaccine Policy is consistent with New Jersey law, which provides that "each health care facility shall establish and implement an annual influenza vaccination program." N.J.S.A. 26:2H-18.79.

The Vaccine Policy requires "Covered Individuals" to be vaccinated and provide proof of the vaccination. "Covered Individuals" includes individuals working in areas where patients receive care. Administrative and service staff are expressly included in the definition of "Covered Individuals." The Vaccine Policy allows for two exemptions: a medical exemption, or a religious exemption. To obtain an exemption, a Covered Individual must complete and submit a request before November 1 of the year for which they are seeking the exemption.

"Covered Individuals" who do not receive an exemption must "provide proof of Seasonal Influenza vaccination prior to the start date of Flu Season[,]" which begins each year on November 1. Any Covered Individual who fails to provide proof of vaccination and who is not exempted, "will not be permitted to work in a Patient Care Area and will be subject to discipline, up to and including termination."

A-2430-24

Rosemary Herrschaft (grievant) worked as a secretary at Rutgers' John H.

Cronin Dental Center. Rutgers maintains that grievant, as an employee working in a health care area, was covered by the Vaccine Policy. In January 2023, Rutgers notified grievant that she had failed to upload proof of seasonal influenza vaccination for the 2022-2023 flu season. Rutgers therefore directed grievant to upload the proof immediately. In response, grievant applied for a religious exemption to the vaccine requirement. Rutgers did not adjudicate the exemption request before the end of the 2022-2023 flu season and, therefore, no action was taken that year. Grievant was notified that she would need to be vaccinated before the next flu season.

In October 2023, grievant reapplied for a religious exemption to the vaccine requirement. In her letter, grievant requested an exemption as a "baptized Catholic." Grievant acknowledged that the Catholic Church "does not prohibit the use of any vaccine, and generally encourages the use of safe and effective vaccines as a way of safeguarding personal and public health [.]" Nevertheless, grievant asserted that she had a moral right to refuse "a medical intervention, including a vaccination, if [her] informed conscience comes to this sure judgment."

A-2430-24

On December 13, 2023, Rutgers notified grievant that her religious exemption had been denied. The notice also directed grievant to obtain the vaccine and demonstrate proof of vaccination within seven days.

On January 2, 2024, Rutgers issued a counseling notice to grievant because she had not provided proof of the seasonal influenza vaccination. The notice stated that grievant's actions violated the Vaccine Policy and her non- compliance would result in discipline, up to and including termination. On January 25, 2024, the University sent grievant a pre-termination notice advising her that there would be a conference to discuss the reasons for her non - compliance with the Vaccine Policy and the possibility of the termination of her employment.

The pre-termination conference was conducted on January 31, 2024, and grievant attended. After considering grievant's request for an exemption from the Vaccine Policy and her contention that the Policy did not apply to her position, Rutgers rejected the request and argument. Thereafter, on March 1, 2024, Rutgers notified grievant she was terminated from employment.

That same day, the International Brotherhood of Teamsters Local 97 (the Union) filed a grievance contesting grievant's termination. The Union is a labor organization that represents certain health care workers employed by Rutgers,

A-2430-24

including the grievant. Rutgers and the Union have a collective negotiation agreement (CNA).

The CNA includes grievance procedures and allows for grievances of "[a]

claimed violation, misinterpretation, or misapplication of rules or regulations, existing policy, or orders of [Rutgers] affecting the terms and conditions of employment." 1 Those procedures also state that a staff member's claim of unjust discipline is governed by the grievance procedures and discipline is defined to include "dismissal from service[.]"

The CNA provides a two-step grievance process. Step one requires a written submission of the grievance to Rutgers' Office of Labor Relations, a hearing, and a decision. If a grievant is not satisfied with the decision after step one, and the grievance involves a material issue such as dismissal, step two allows the grievant to request arbitration before a neutral arbitrator.

On May 1, 2024, the Union submitted a request for binding arbitration of the grievance to the Commission. The Union sought to have an arbitrator selected to conduct binding arbitration of the disciplinary grievance.

1 The record on this appeal includes the CNA covering the period from July 1, 2018 through June 30, 2022. No party disputes that the grievance procedures set forth in that CNA cover, possibly through extension, the Union's grievance on behalf of grievant.

A-2430-24

On October 29, 2024, Rutgers filed a petition with the Commission for a scope of negotiation determination seeking to restrain binding arbitration of the grievance. In support of its petition, Rutgers submitted three certifications explaining the reason for its Vaccine Policy and why it believed the policy was not subject to binding arbitration. The Union opposed Rutgers' petition and submitted a certification in support of its opposition.

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