Washington Teachers' Union v. District of Columbia Public Schools

960 A.2d 1123, 2008 D.C. App. LEXIS 476, 2008 WL 5082915
CourtDistrict of Columbia Court of Appeals
DecidedDecember 4, 2008
Docket06-CV-1071, 06-CV-1072
StatusPublished
Cited by12 cases

This text of 960 A.2d 1123 (Washington Teachers' Union v. District of Columbia Public Schools) is published on Counsel Stack Legal Research, covering District of Columbia Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Washington Teachers' Union v. District of Columbia Public Schools, 960 A.2d 1123, 2008 D.C. App. LEXIS 476, 2008 WL 5082915 (D.C. 2008).

Opinion

REID, Associate Judge:

This case involves a dispute as to whether the Superior Court (“the trial court”) or the Office of Employee Appeals (“OEA”) should exercise initial jurisdiction over appellants’ claims, as they are articulated in separate complaints filed by the Washington Teachers’ Union, Local # 6 (“WTU”) and the American Federation of State, County and Municipal Employees, District Council 20, Local 2921, AFL-CIO (“AFSCME”) (collectively, “appellants”). In their respective complaints, appellants alleged that appellees, the District of Columbia Public Schools (“DCPS”), the Superintendent of the District of Columbia Public Schools (then Clifford B. Janey) (“the Superintendent”), and the District of Columbia Board of Education (“the Board”) (collectively, “appellees”), violated the Comprehensive Merit Personnel Act (“CMPA”) by improperly eliminating jobs and terminating around 700 teachers and school-based personnel (‘WTU lawsuit”) and about 26 Union-represented school employees — clerical employees and educational aides — (“AFSMCE lawsuit”), through a 2004 reduction in force (“RIF”). 1 Appellants appeal from the trial court’s order granting appellees’ motion to dismiss their complaints.

We hold that appellants must present their claims in the first instance to OEA. We further hold, in general agreement with the trial court, that the Abolishment Act procedures, imposed for budgetary reasons, appear to apply to the 2004 RIF, rather than the general RIF provisions of the CMPA. We also conclude that instead of dismissing appellants’ complaints, the trial court should have stayed its proceedings and transferred the case to the OEA for a determination of OEA’s jurisdiction; and for initial resolution of appellants’ claims, if OEA confirms its jurisdiction. Accordingly, we remand the case to the trial court for a stay of proceedings and a transfer of the case to the OEA.

FACTUAL SUMMARY

The record before us shows that on October 22, 2004, and November 10, 2004, WTU and AFSCME, respectively, filed virtually identical complaints in the trial court. They alleged that in May of 2004, the DCPS notified approximately 700 teachers and school-based personnel, 2 and *1126 approximately 26 Union-represented employees, that their positions were being abolished in a RIF, 3 effective June 30, 2004. 4 The abolishment was conducted in accordance with the Abolishment Act, D.C.Code § 1-624.08 5 (Repl.2006), 6 and *1127 the Board’s regulations governing “the termination of the employment of employees of the Board ... due to the lack of funds, lack of work, or reorganization of functions,” 5 DCMR. § 1500.1, and other provisions of Chapter 15. Specifically, appellants alleged in Count I of their complaints, that DCPS and the Superintendent violated D.C.Code § l-624.08(d) “by conducting an abolishment of [employees] ... and denying one round of lateral competition in accordance with Chapter 24 of the District of Columbia Personnel Manual.” Count II asserted that the Board of Education violated D.C.Code § l-608.01a (b)(2)(L)(i) of the CMPA, 7 “by failing to *1128 issue rules and regulations which provide for RIF procedures with a prescribed order of separation based on tenure of appointment and length of service; and which provide for priority re-employment consideration.” Count III claimed that the Board “acted beyond the scope of its statutory authority, in violation of [D.C.Code] § l-608.01a (b)(2)(L)(i) by issuing the RIF regulations contained in 5 DCMR, Chapter 15, which preclude separation based on tenure of employment and length of service and which deny employees the right to priority re-employment consideration.” In their prayer for relief, appellants, in part, sought an order compelling appellees (1) “to comply with all applicable provisions of the CMP A, specifically §§ l-608.01a (b)(2)(L)(i), 1-624.02, 8 *1129 and 1-624.08”; (2) “to rescind the current regulations contained in Title 5, Chapter 15 of the DCMR”; (3) “to provide for one level of lateral competition based on retention standing and priority re-employment consideration ... for all teachers and employees affected by the 2004 abolishment”; and (4) “to make whole all affected employees[.]”

On July 16, 2005, appellees filed a motion to dismiss appellants’ complaints pursuant to Super. Ct. Civ. R. 12(b)(6). After listening to the arguments of the parties at a hearing on July 26, 2006, the Honorable Leonard Braman agreed with appellees that CMPA requires appellants’ claims to be presented to the OEA. In addition, the trial court stated that the general RIF procedures found in D.C.Code § 1-624.02 were inapplicable to this matter. Rather, said the trial judge, the RIF procedures under the Abolishment Act applied, and the general RIF procedures were “in a state of suspension” while the Abolishment Act was in effect. That is, “the Abolishment Act displaces the general RIF statute[,]” or “suspends it while the fiscal emergency continues.” The trial court determined that under the Abolishment Act’s RIF procedures, D.C.Code § l-624.08(d) entitles an affected employee, who otherwise would be eligible to compete for retention, “to one round of lateral competition”; and D.C.Code § l-624.08(e) calls for a thirty-day notice of the proposed separation. Furthermore, the trial court declared that under D.C.Code § 1-624.08(f)(2), an affected employee is authorized to file an appeal with OEA. After examining the counts in appellants’ complaints, the trial court decided that OEA has jurisdiction over each of the counts, not the trial court. Consequently, the court orally granted appellants’ motion to dismiss. Following the hearing, the trial court issued a short written order, which referenced the hearing and concluded that it lacked subject matter jurisdiction. Appellants filed notices of appeal.

ANALYSIS

Appellants contend that the trial court erred in dismissing their complaints on the ground that OEA has jurisdiction over their claims. They argue that their “claims ...

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Bluebook (online)
960 A.2d 1123, 2008 D.C. App. LEXIS 476, 2008 WL 5082915, Counsel Stack Legal Research, https://law.counselstack.com/opinion/washington-teachers-union-v-district-of-columbia-public-schools-dc-2008.