Orange Twp. v. Internatl. Assn. of Fire Fighters Local 3816

2022 Ohio 2757
CourtOhio Court of Appeals
DecidedAugust 8, 2022
Docket21 CAE 070033
StatusPublished
Cited by2 cases

This text of 2022 Ohio 2757 (Orange Twp. v. Internatl. Assn. of Fire Fighters Local 3816) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Orange Twp. v. Internatl. Assn. of Fire Fighters Local 3816, 2022 Ohio 2757 (Ohio Ct. App. 2022).

Opinion

[Cite as Orange Twp. v. Internatl. Assn. of Fire Fighters Local 3816, 2022-Ohio-2757.]

COURT OF APPEALS DELAWARE COUNTY, OHIO FIFTH APPELLATE DISTRICT

ORANGE TOWNSHIP, OHIO : JUDGES: : Hon. Craig R. Baldwin, P.J. Plaintiff-Appellant : Hon. Patricia A. Delaney, J. : Hon. Earle E. Wise, Jr., J. -vs- : : IAFF LOCAL 3816 : Case No. 21 CAE 070033 : Defendant-Appellee : OPINION

CHARACTER OF PROCEEDING: Appeal from the Court of Common Pleas, Case No. 20 CVH 120554

JUDGMENT: Affirmed

DATE OF JUDGMENT: August 8, 2022

APPEARANCES:

For Plaintiff-Appellant For Defendant-Appellee

BRIAN M. ZETS HENRY A. ARNETT BENJAMIN D. HUMPHREY COLLEEN M. ARNETT Two Miranova Place 1335 Dublin Road Suite 700 Suite 108-B Columbus, OH 43215 Columbus, OH 43215 Delaware County, Case No. 21 CAE 070033 2

Wise, Earle, J.

{¶ 1} Appellant, Orange Township, Ohio, appeals the June 4, 2021 judgment

entry of the Court of Common Pleas of Delaware County, Ohio, granting the motion to

confirm arbitration award filed by appellee, International Association of Fire Fighters,

Local 3816.

FACTS AND PROCEDURAL HISTORY

{¶ 2} In October 2016, Marcus Musser started working as a part-time firefighter

for appellant and was assigned to 1-Unit at Station 361. The grievants herein are fellow

firefighter Bradley Belville and appellant's chain of command, Lieutenant David Martin

and Captain John Hodges. In September 2019, Musser requested a transfer and was

subsequently transferred to 2-Unit.

{¶ 3} Fire Chief Matt Noble interviewed Musser regarding his transfer request.

Thereafter, Chief Noble conducted an investigation, held predisciplinary hearings, and in

reports dated December 5, 2019, recommended the termination of the grievants for

violating several sections of the Orange Township policies including threats or acts of

physical violence against a coworker, abusive behavior, hazing, harassment of a

coworker, conduct unbecoming, neglect of duty, and failure to meet essential job

functions.

{¶ 4} On December 9, 2019, the Orange Township Trustees held a special

meeting to consider the Fire Chief's recommendation. The trustees adopted the Fire

Chief's findings and recommendation and terminated the grievants.

{¶ 5} On December 11, 2019, the grievants, represented by appellee, filed a

grievance contesting their terminations. Arbitration hearings were held on August 20, and

21, 2020. By award dated November 6, 2020, the arbitrator found appellant did not have Delaware County, Case No. 21 CAE 070033 3

just cause to terminate the grievants and ordered the grievants be reinstated to their

positions with no loss of seniority, receive back pay, and have their records expunged

regarding their terminations. Specifically, the arbitrator found 1) there was insufficient

evidence of "unwelcome harassment, hazing, bullying, or physical assault," 2) the

grievants were not afforded proper due process, and 3) appellant did not put grievants on

notice of the disciplinary consequences of their behavior.

{¶ 6} On December 7, 2020, appellant filed a motion and an application with the

trial court to vacate or modify the arbitration award. On January 7, 2021, appellee filed a

counterclaim and a motion to confirm the award. By judgment entry filed June 4, 2021,

the trial court denied appellant's application and granted appellee's counterclaim,

confirming the award.

{¶ 7} Appellant filed an appeal. This matter is now before this court for

consideration. Assignment of error is as follows:

I

{¶ 8} "THE TRIAL COURT ERRED WHEN IT CONFIRMED THE

ARBITRATOR'S AWARD AND FAILED TO VACATE OR MODIFY THE AWARD."

{¶ 9} In its sole assignment of error, appellant claims the trial court erred in

confirming the arbitrator's award.

{¶ 10} In its application to the trial court, appellant argued the arbitrator modified

the collective bargaining agreement (hereinafter "CBA") and/or exceeded his powers in

his determination under R.C. 2711.10(D) which states: "the court of common pleas shall

make an order vacating the award upon the application of any party to the arbitration if: Delaware County, Case No. 21 CAE 070033 4

[t]he arbitrators exceeded their powers, or so imperfectly executed them that a mutual,

final, and definite award upon the subject matter submitted was not made."

{¶ 11} Pursuant to R.C. Chapter 2711, a trial court may confirm, vacate, or modify

an arbitrator's award; however, as explained in Board of Education of Findlay City School

District v. Findlay Education Association, 49 Ohio St.3d 129, 551 N.E.2d 186 (1990),

syllabus:

1. Given the presumed validity of an arbitrator's award, a reviewing

court's inquiry into whether the arbitrator exceeded his authority, within the

meaning of R.C. 2711.10(D), is limited.

2. Once it is determined that the arbitrator's award draws its essence

from the collective bargaining agreement and is not unlawful, arbitrary or

capricious, a reviewing court's inquiry for purposes of vacating an

arbitrator's award pursuant to R.C. 2711.10(D) is at an end. (R.C.

2711.10[D], construed and applied.)

{¶ 12} " '[A]n arbitrator's award departs from the essence of a collective bargaining

agreement when: (1) the award conflicts with the express terms of the agreement, and/or

(2) the award is without rational support or cannot be rationally derived from the terms of

the agreement.' " City of Alliance v. FOP/Ohio Labor Council, Inc., 5th Dist. Stark No.

2002CA00195, 2003-Ohio-223, ¶ 20, quoting Ohio Office of Collective Bargaining v. Ohio

Civil Service Employees Association, Local 11, 59 Ohio St.3d 177, 572 N.E.2d 71 (1991),

syllabus. "An arbitrator's award draws its essence from a collective bargaining agreement

when there is a rational nexus between the agreement and the award, and where the Delaware County, Case No. 21 CAE 070033 5

award is not arbitrary, capricious or unlawful." Mahoning County Board of Mental

Retardation & Developmental Disabilities v. Mahoning County TMR Education

Association, 22 Ohio St.3d 80, 488 N.E.2d 872 (1986), paragraph one of the syllabus.

{¶ 13} As explained by the Supreme Court of Ohio in Goodyear Tire & Rubber Co.

v. Local Union 200, 42 Ohio St.2d 516, 520, 330 N.E.2d 703 (1975):

Were the arbitrator's decision to be subject to reversal because a

reviewing court disagreed with findings of fact or with an interpretation of

the contract, arbitration would become only an added proceeding and

expense prior to final judicial determination. This would defeat the bargain

made by the parties and would defeat as well the strong public policy

favoring private settlement of grievance disputes arising from collective

bargaining agreements.

Ohio's statutory scheme in R.C. 2711.10 thus limits judicial review of

arbitration to claims of fraud, corruption, misconduct, an imperfect award,

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