Matter of Susquehanna Valley Cent. School Dist. v. Susquehanna Valley Teachers’ Ass’n, 90 N.Y.2d 793 (1997)
When a public employer unilaterally changes a term of employment expressly covered by a collective bargaining agreement (CBA), the dispute is resolved through the CBA’s grievance procedures, not the Public Employment Relations Board (PERB).
Summary
The Susquehanna Valley Central School District reduced the work hours of its matrons, violating a CBA provision specifying an eight-hour workday. The matrons filed a grievance, which was denied. They then initiated an Article 78 proceeding, arguing the reduction was arbitrary. The School Board, for the first time on appeal, claimed the court lacked jurisdiction because the issue fell under PERB’s exclusive jurisdiction as a failure to negotiate in good faith under the Taylor Law. The Court of Appeals held that because the CBA expressly covered the working hours, the dispute was a breach of contract, not a failure to negotiate, and thus was properly resolved through the CBA’s grievance process, not PERB.
Facts
The Susquehanna Valley Central School District employed petitioners as school matrons. The school district reduced the matrons’ daily work schedule from eight to six hours. The collective bargaining agreement (CBA) specified that changes in working conditions must be negotiated and agreed upon in writing and that matrons would normally work an eight-hour day. The matrons filed a grievance claiming a breach of the CBA.
Procedural History
The matrons’ grievance was denied at all stages, including a hearing before the Board of Education. The matrons then filed a CPLR Article 78 proceeding challenging the Board of Education’s determination. Supreme Court ruled in favor of the matrons, ordering restoration of their full-time hours. The school board appealed, arguing that Supreme Court lacked subject matter jurisdiction, asserting the issue was within PERB’s exclusive jurisdiction. The Appellate Division agreed with the school board. The Court of Appeals reversed the Appellate Division’s decision, reinstating the Supreme Court’s judgment.
Issue(s)
Whether a public employer’s unilateral change in a term of employment expressly covered by a collective bargaining agreement (CBA) falls within the exclusive jurisdiction of the State Public Employment Relations Board (PERB), or whether it may be resolved through the grievance procedures of the CBA.
Holding
No, because when a collective bargaining agreement (CBA) already covers a specific term of employment, a dispute over that term is a breach of contract issue to be resolved through the CBA’s grievance procedures, not a failure to negotiate issue falling under the Public Employment Relations Board’s (PERB) jurisdiction.
Court’s Reasoning
The Court of Appeals reasoned that the Taylor Law does not override basic contract law. Once a CBA is in place, the statutory duty to bargain is exhausted for the terms expressly covered in the agreement. Citing Matter of City of Newburgh v Newman, the court distinguished between disputes arising from terms already agreed upon in the CBA (resolvable through grievance/arbitration) and disputes concerning new matters (requiring bargaining). The court also noted Civil Service Law § 205 (5) (d), which restricts PERB’s jurisdiction, stating that “the board shall not have authority to enforce an agreement between an employer and an employee organization and shall not exercise jurisdiction over an alleged violation of such an agreement that would not otherwise constitute an improper employer or employee organization practice.” The court emphasized that PERB itself has recognized that disputes over subjects settled by the CBA are outside its jurisdiction. The court reasoned that because the matrons’ work hours were covered by the CBA, the school district’s unilateral change was a breach of the CBA, not an improper practice of failure to bargain in good faith. The court concluded that the dispute centered on interpreting the CBA, specifically whether the eight-hour workday provision was an enforceable job security clause and whether management rights provisions justified the reduction in hours. These were contractual issues beyond PERB’s jurisdiction. The court stated, “In all respects, the rights asserted by the parties to this controversy are derived from exchanges of promises in the CBA.”