Board of Education, Great Neck Union Free School District v. Great Neck Teachers Association, 51 N.Y.2d 338 (1980)

When a collective bargaining agreement contains a broad arbitration clause covering disputes involving the interpretation or application of the agreement, the question of whether a particular dispute falls within the scope of the substantive provisions of the contract is itself a matter for the arbitrator to decide.

Summary

The Great Neck Union Free School District sought to stay arbitration of a probationary teacher’s grievance, arguing the dispute was not covered by the collective bargaining agreement’s substantive provisions. The New York Court of Appeals held that because the agreement contained a broad arbitration clause covering the interpretation and application of its provisions, the arbitrator, not the court, should determine whether the grievance fell within the contract’s scope. Restrictions on the arbitrator’s power relate to remedies, not the initial determination of arbitrability.

Facts

The Great Neck Union Free School District (the “District”) and the Great Neck Teachers Association (the “Association”) had a collective bargaining agreement. This agreement included a clause submitting to arbitration all grievances involving an alleged misinterpretation or misapplication of an express provision of the agreement. A probationary teacher filed a grievance based on alleged violations of the contract’s disciplinary provisions. The District sought to stay arbitration, arguing the grievance was not arbitrable.

Procedural History

The School District sought a stay of arbitration. The lower courts initially sided with the School District, but the Court of Appeals reversed, finding the dispute arbitrable. The Court of Appeals held that the question of whether the grievance fell within the agreement’s substantive provisions was for the arbitrator to decide, given the broad arbitration clause.

Issue(s)

Whether a court should stay arbitration when the parties’ agreement to arbitrate is clear and unequivocal, but there is ambiguity as to whether the applicable substantive provision of the contract covers the particular dispute.

Holding

No, because when the parties’ agreement to arbitrate the dispute is clear and unequivocal, the arbitrator should decide the scope of the substantive provisions of the contract. The Court reasoned that interpreting the scope of those provisions is itself a matter of contract interpretation, which the parties have agreed to submit to arbitration.

Court’s Reasoning

The Court of Appeals emphasized the broad language of the arbitration clause in the collective bargaining agreement. The agreement provided for arbitration of “all grievances involving ‘an alleged misinterpretation or misapplication of an express provision of [the] Agreement’”. The court stated that the question of whether the grievance fell within the scope of the substantive provisions of the contract was itself “a matter of contract interpretation and application, and hence it must be deemed a matter for resolution by the arbitrator.” The court distinguished its prior holding in Matter of Acting Supt. of Schools of Liverpool Cent. School Dist. [United Liverpool Faculty Assn.], noting that in Liverpool, the arbitration agreement itself did not unambiguously extend to the particular dispute. Here, the arbitration agreement was broad and clear. The court also addressed the District’s argument that limitations on the arbitrator’s power (e.g., not varying the terms of the agreement) justified staying arbitration. The Court rejected this argument, stating that these restrictions were merely instructions to the arbitrator on remedies, not limitations on the scope of arbitrable issues. The court noted, “Since it cannot be assumed in advance of arbitration that the arbitrator will exceed his powers as delimited in the agreement, the restrictive language in the arbitration clause cannot be cited as a ground for staying arbitration”. The court directly quoted the contract, noting “The arbitrator shall limit his decision strictly to the interpretation or application of the express provision of this agreement submitted to him and he shall be without power or authority to make any decision…contrary to, or inconsistent with, or modifying or varying in any way, the terms of this agreement”.