Rockford Public Schools, District No. 205 v. Illinois Educational Labor Relations Board, State Panel

2025 IL App (4th) 231542-U
CourtAppellate Court of Illinois
DecidedFebruary 13, 2025
Docket4-23-1542
StatusUnpublished

This text of 2025 IL App (4th) 231542-U (Rockford Public Schools, District No. 205 v. Illinois Educational Labor Relations Board, State Panel) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rockford Public Schools, District No. 205 v. Illinois Educational Labor Relations Board, State Panel, 2025 IL App (4th) 231542-U (Ill. Ct. App. 2025).

Opinion

NOTICE 2025 IL App (4th) 231542-U FILED This Order was filed under February 13, 2025 Supreme Court Rule 23 and is NO. 4-23-1542 Carla Bender not precedent except in the 4th District Appellate limited circumstances allowed IN THE APPELLATE COURT Court, IL under Rule 23(e)(1).

OF ILLINOIS

FOURTH DISTRICT

ROCKFORD PUBLIC SCHOOLS, DISTRICT NO. ) Review of Order of the Illinois 205, ) Educational Labor Relations Petitioner, ) Board v. ) No. 23-RS-0017-C THE ILLINOIS EDUCATIONAL LABOR ) RELATIONS BOARD, STATE PANEL, and ) ROCKFORD BUILDING MAINTENANCE ) ASSOCIATION, IEA-NEA, ) Respondents. ) ______________________________________________________________________________

PRESIDING JUSTICE HARRIS delivered the judgment of the court. Justices Steigmann and Cavanagh concurred in the judgment.

ORDER

¶1 Held: The Illinois Educational Labor Relations Board did not err in finding that a group of school district employees had a sufficient community of interest with employees in an existing bargaining unit and that the two groups formed an appropriate bargaining unit.

¶2 Petitioner, Rockford Public Schools, District No. 205 (District), seeks

administrative review of a decision of the Illinois Educational Labor Relations Board, State Panel

(Board), granting a petition filed by the Rockford Building Maintenance Association, IEA-NEA

(Union), to add a group of District employees to an existing bargaining unit represented by the

Union and certifying the Union’s proposed new bargaining unit. The District appeals, arguing the

Board erred in finding the proposed bargaining unit was appropriate. We affirm.

¶3 I. BACKGROUND ¶4 The District and the Union are parties to a collective bargaining agreement (CBA),

effective from July 1, 2022, through June 30, 2026. In December 2022, the Union filed a

self-determination majority interest petition with the Board pursuant to section 7(c) of the Illinois

Educational Labor Relations Act (Act) (115 ILCS 5/7(c) (West 2022)), alleging that a group of

District employees wanted to be added to an existing bargaining unit of District employees that

the Union already represented. Specifically, the Union proposed adding the position of

“Technology Specialist I”—referred to by the parties as “Field Techs”—to a bargaining unit with

the following composition, as agreed by the parties:

“All full-time non-certified educational employees in the categories of Building

Engineers, Custodians, Assistant Building Engineers, Program Supervisors, Driver

Trainers, Dispatchers, Field Supervisors, Steamfitters, [Heating, Ventilation, and

Air Conditioning (HVAC)] Technicians, Stockroom Employees, Truck Drivers,

Truck Helpers, Printers, Painters, Electricians, Plumbers, Carpenters, Locksmiths,

Environmental Technicians, Low Voltage Electricians, Site Maintenance

Employees, Mechanics, Generator Mechanics, Body Shop Technicians, Bus

Maintenance Specialists, State Inspection/Bus Wash Employees, Preparation

Specialists, Relief Personnel, Small Motor Repairment[,] and Transportation Parts

Persons employed by [the District].”

¶5 In January 2023, the District filed a response, opposing the Union’s petition. It

argued the Union’s proposed bargaining unit was “not appropriate” because there was “no

historical pattern of recognition between the original unit and the proposed additional position.”

The District also asserted there was “no community of interest” between the two groups due to

Field Techs and bargaining unit members having different duties, departments and supervision,

-2- educational requirements, and pay. Alternatively, the District argued that if Field Techs were

included in the existing bargaining unit, the unit would only be appropriate if “all equivalent

technology support-related positions” were also included.

¶6 In May 2023, a hearing on the Union’s petition was conducted before an

Administrative Law Judge (ALJ). The Union presented testimony from two witnesses: (1) Scott

Phelps, its president and a distribution foreperson for the District, and (2) Logan Sprecher, a

District employee in the Field Tech position. The District presented testimony from several

witnesses: (1) Matthew Zediker, its chief human resources officer; (2) Jason Barthel, its chief

information officer; (3) Andrew Lippert, its director of technology services; (4) Christopher

Gulley, a Field Tech; (5) Andrew Flowers, a help desk specialist; and (6) Michael Phillips, its chief

operating officer. The parties submitted exhibits, which included job descriptions of the relevant

positions. Their prehearing filings also included a joint statement of uncontested facts.

¶7 Evidence showed the District was comprised of over 40 buildings, including school

buildings, an administration building, an Operations Support Center, and a transportation building.

Under the District’s organizational structure, all District employees were under the authority of

the superintendent. The superintendent directly oversaw several cabinet member positions,

including a chief operating officer and a chief information officer. In turn, each cabinet member

oversaw various departments, and each department also had its own supervisors. Bargaining unit

positions fell within the facilities, logistics and support services (also referred to as distribution),

and transportation departments, which all reported to the District’s chief operating officer. Field

Techs fell within the technology services department, which reported to the District’s chief

information officer.

¶8 Zediker, the District’s chief human resources officer, estimated that 90 District

-3- employees were current bargaining unit members represented by the Union. He testified that the

vast majority of the bargaining unit positions were funded out of “Fund 10 or local dollars.”

Evidence showed that bargaining unit positions in the District’s facilities department were

responsible for maintaining the District’s heating, cooling, plumbing, electrical, and

communication systems. Some of these positions were also responsible for maintaining the

interiors and exteriors of the District’s buildings. Bargaining unit employees in the District’s

transportation department maintained and oversaw the use of the District’s buses and other

vehicles. Finally, bargaining unit employees in the District’s logistics and support services

department were responsible for organizing, transporting, and unloading supplies, equipment, and

other materials within the District.

¶9 The education and experience required of bargaining unit positions varied. Union

President Phelps testified some unit members were required to hold skill-based licenses or industry

certifications. For example, he noted that there were bargaining unit members who held

commercial driver’s licenses, were licensed electricians, or were certified HVAC technicians. The

District’s job description for “HVAC Technicians/Electrician” indicated it preferred that such

employees have an associate’s degree in electronics. The District also preferred apprenticeship

experience for some bargaining unit positions. Many positions required that employees have a high

school diploma or a GED, along with practical experience. Other positions, specifically those

within the District’s print shop, had no specific licensing, educational, or experience-related

requirements.

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2025 IL App (4th) 231542-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rockford-public-schools-district-no-205-v-illinois-educational-labor-illappct-2025.