Board of Education v. Patchogue-Medford Congress of Teachers, 48 N.Y.2d 812 (1979)
Once it is determined that a grievance falls within the scope of a collective bargaining agreement’s arbitration clause and arbitration would not violate public policy, further judicial inquiry is foreclosed, and questions of res judicata are within the arbitrator’s exclusive province.
Summary
The Board of Education sought to stay arbitration of a grievance filed by the Patchogue-Medford Congress of Teachers concerning denied sabbatical leaves and summer study grants. The Board argued that a prior arbitration award denying similar grievances for different teachers was res judicata. The Court of Appeals held that because the grievance fell within the scope of the collective bargaining agreement’s broad arbitration clause and arbitration wouldn’t violate public policy, the question of whether the prior award barred the current grievance was for the arbitrator to decide.
Facts
The Patchogue-Medford Congress of Teachers (the Union) filed a grievance asserting that the Board of Education (the Board) improperly denied sabbatical leaves and summer study grants to 22 teachers, violating their collective bargaining agreement. Previously, a similar grievance had been filed on behalf of four different teachers seeking the same relief, and an arbitrator had denied that prior grievance.
Procedural History
The Union sought to submit the new dispute to arbitration. The Board commenced a proceeding to stay the arbitration, arguing that the prior 1974 award was res judicata and barred the new grievance. The lower courts’ decisions are not specified, but the Court of Appeals affirmed the Appellate Division’s order, which presumably allowed the arbitration to proceed.
Issue(s)
Whether a prior arbitration award denying grievances of different teachers seeking similar relief under the same collective bargaining agreement is res judicata and thus bars arbitration of a subsequent, similar grievance; and, if not, whether the application of res judicata is an issue for the court or the arbitrator to decide.
Holding
No, because the grievance falls within the scope of the collective bargaining agreement’s arbitration clause and arbitration wouldn’t violate public policy; therefore, the question of whether the prior award constitutes a bar to the relief sought is within the exclusive province of the arbitrator to resolve.
Court’s Reasoning
The Court of Appeals relied on the principle established in Matter of Acting Supt. of Schools of Liverpool Cent. School Dist. [United Liverpool Faculty Assn.], 42 NY2d 509, 513, stating that once it is determined that the grievance falls within the scope of the arbitration clause and that arbitration would not violate public policy, further judicial inquiry is foreclosed. The court emphasized that any remaining questions, including the applicability of res judicata, are within the arbitrator’s exclusive jurisdiction. The court cited Binghamton Civ. Serv. Forum v City of Binghamton, 44 NY2d 23, 28-29 and Rochester City School Dist. v Rochester Teachers Assn., 41 NY2d 578, 582-583 to support this proposition. The court reasoned that parties agree to submit disputes to arbitration, and the arbitrator is best positioned to determine how prior awards affect subsequent grievances under the same agreement. The court notes, “Inasmuch as petitioner concedes that the grievance is within the scope of the broad arbitration clause in the collective bargaining agreement and that arbitration of the dispute would do no violence to the expressed public policy of the State, further judicial inquiry is foreclosed”. The ruling emphasizes the importance of respecting the arbitration process agreed upon by the parties in collective bargaining agreements. This decision limits judicial intervention in arbitration matters,deferring to the arbitrator’s expertise in interpreting the collective bargaining agreement and determining the preclusive effect of prior awards in subsequent disputes between the same parties under the same contract.