Franklin Central School v. Franklin Teachers Ass’n, 51 N.Y.2d 353 (1980)

When a collective bargaining agreement contains a broad arbitration clause, the question of whether a substantive provision of the agreement entitles a grievant to relief is for the arbitrator to decide, not the court.

Summary

This case concerns whether a non-teaching employee (a school nurse) who becomes part of a teachers’ collective bargaining unit can arbitrate disputes under the agreement. The Court of Appeals held that once it’s determined an agreement to arbitrate exists, and the dispute falls within the scope of the arbitration clause, the arbitrator decides whether the substantive terms of the agreement apply to the employee. This includes disputes over salary and termination, even if the employer argues the employee isn’t covered by specific provisions.

Facts

Ruth Laing was initially employed as a school nurse-teacher, a teaching position, and was a member of the Franklin Teachers Association. Her position was abolished and replaced with a civil service position of school nurse, which she was offered. As part of a settlement resolving an improper practice charge, the school district agreed that the new school nurse position would be part of the teachers’ bargaining unit for negotiations. Laing’s salary was substantially reduced in the new role. The Teachers Association filed grievances regarding her salary and later her termination, arguing she was terminated without “just cause” as required by the collective bargaining agreement.

Procedural History

The Teachers Association demanded arbitration for both the salary grievance and the termination grievance. The school district sought a stay of both arbitrations. The Supreme Court denied the stay for the salary grievance but granted it for the termination grievance, reasoning that the