Trotwood Madison Classroom Teachers Ass'n v. Trotwood Madison City School Dist. Bd. of Education

367 N.E.2d 1233, 52 Ohio App. 2d 39, 6 Ohio Op. 3d 22, 96 L.R.R.M. (BNA) 3148, 1977 Ohio App. LEXIS 6937
CourtOhio Court of Appeals
DecidedMay 4, 1977
Docket5424
StatusPublished

This text of 367 N.E.2d 1233 (Trotwood Madison Classroom Teachers Ass'n v. Trotwood Madison City School Dist. Bd. of Education) 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
Trotwood Madison Classroom Teachers Ass'n v. Trotwood Madison City School Dist. Bd. of Education, 367 N.E.2d 1233, 52 Ohio App. 2d 39, 6 Ohio Op. 3d 22, 96 L.R.R.M. (BNA) 3148, 1977 Ohio App. LEXIS 6937 (Ohio Ct. App. 1977).

Opinion

McBride, J.

This action was initiated by the Trotwood Madison Teachers Association against the board of education for a mandatory injunction and declaratory judgment seeking to enforce provisions (1) for an advisory board provided in a recognition and negotiating understanding and (2) for grievance procedure in a separate contract entered into by the board of education with its employees. The board responded with several defenses; however, the chief defense asserted that the provision for an advisory board in the preliminary understanding was withdrawn, as expressly authorized, and that grievance provisions in the old contract, if still effective, were not applicable to anything not within the terms of the executed contract.

The hearing began on the motion for a preliminary injunction and was interrupted when the parties stipulated the facts that appear in an unsigned five page record filed *40 December 8,1976. Tbe record narrowly confines tbe facts to tbe two questions asserted by tbe complainant and denied by tbe defendant.

Tbe trial judge found' that tbe board bad a legal right under Article I, Paragraph 5, of the original understanding “to do what it is alleged to have done,” that is, withdraw tbe use of an advisory board during negotiations, and that complainant bad no cause of action. Injunctions were denied and tbe complaint was dismissed. The court incorporated tbe stipulations of tbe parties as its finding of facts. It did not expressly rule on the question of tbe use of tbe compulsory grievance procedure in tbe former contract to compel tbe use of an advisory board in negotiations for a new contract; however, in view of tbe finding and judgment it must be assumed that this was also denied.

Tbe complainants appealed asserting two grounds of error:

1. The denial of plaintiff’s prayer for injunctive relief and tbe dismissal of tbe complaint;

2. Tbe dismissal of tbe complaint without ruling on plaintiff’s request for declaratory relief and without making findings as to defendant’s failure to comply with grievance procedure.

There is in ibis case an overdose of mixed rhetoric, the clarification of which assists in understanding tbe problem. Tbe parties are a board of education and a teachers association. In January of 1976, they began negotiations on a new contract of employment for those involved. Their negotiations in tbe first stage of reaching a contract were guided by a recognition and policy understanding which outlined the * ‘negotiation policy” to be followed in negotiating a new agreement.

This initial process in educational relations may have an historical origin because the recognition of a union and a method for reaching an agreement within the context of the law in this virginal field of public labor relations presented handicaps. Private corporations and individuals have no problems, but how, when and if a public agency enters a contract, in the absence of legislation, is a unique assignment that is often expressed by initial undertakings *41 by boards and public authorities to indicate how and under what conditions it will enter into negotiations leading to a legal contract.

The distinction is clear in Dayton Teachers Assn. v. Dayton Bd. of Edn. (1975), 41 Ohio State 2d 127, which involved a final negotiated contract into which the board and the association had entered, including binding arbitration. At issue in that case were grievances concerning the terms and working conditions of the individual members of the association under the existing contract. The court had before it a case where the board had entered into am executed, binding contract. The only issue was whether the executed contract was lawful and could be enforced. This stage was not reached in the instant case.

The first stage involves the authority of and methods used by the board in carrying out its public responsibility when it seeks to enter into such a contract. Unions have entered into this area of administration probably because recognition as a bargaining agent is the first step in its position. Naturally, they sought the best possible position, which involves the imposition of restrictions on the authority of such boards to enter into contracts such as was executed in the Teachers Assn. case. This involvement by unions in the authority and procedure of school boards to enter into a pact with its teachers is represented by some form of understanding of preliminary negotiating procedures or policies which hopefully will eventually lead to an executed contract for the employees. The cases suggest that where such preliminary “policies” are accepted, boards have been cautious in varying degrees to protect their right to control the acceptance or rejection of contracts. While a board may accept a contract containing compulsory arbitration of grievances under its terms, there has not yet appeared any authority for the creation of a contract by compulsory arbitration. Indeed, the initiation of a contract by compulsion is foreign to any understanding of contract law.

With this preliminary background, it is apparent that the preliminary “negotiating policy” provided for the eventual creation of an advisory board for arbitration where an agreement upon a contract had not been reached. *42 The hoard was required to consider its recommendations hut was not hound to accept it. (Article IV, Paragraph II.) In addition, in Article I, Paragraph 5, there appears a reservation of authority, as follows:

“If, however, in the judgment of the Board of Education the [negotiating] procedure so established is not functional or the purpose of the procedure has been frustrated, the Board maintains its right to alter, revise or discontinue the procedure, or take such other action as it feels will be in the best interest of the educational enterprise [in negotiating or accepting a contract].”

After some negotiations, the board on, February 11, 1976, by resolution discontinued the negotiating procedure pursuant to its authority under Article I, Paragraph 5.

The last executed employee contract contained a provision for the compulsory arbitration of grievances involving negotiated policies entered into and agreed hy the board and the teachers. In March, the association itself presented a grievance and demanded compulsory arbitration against the board, based upon its discontinuance of the above portion of the negotiation policy. The demand of the association for a compulsory review panel under the executed contract was ignored and resulted in the present lawsuit. In April 1976, the board indicated that the matter alleged in the notice was not “grievable.”

The position of the board is (1) that its discontinuance action was expressly authorized in the preliminary recognition and negotiating policy statement and (2) that a grievance could only relate to matters “negotiated and agreed to” in an executed contract and had no application to recognition and negotiating procedures designed to facilitate an entry into such contracts. We agree with this construction.

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Bluebook (online)
367 N.E.2d 1233, 52 Ohio App. 2d 39, 6 Ohio Op. 3d 22, 96 L.R.R.M. (BNA) 3148, 1977 Ohio App. LEXIS 6937, Counsel Stack Legal Research, https://law.counselstack.com/opinion/trotwood-madison-classroom-teachers-assn-v-trotwood-madison-city-school-ohioctapp-1977.