New York Law Review

Central Square Teachers Assn. v. Bd. of Educ., 52 N.Y.2d 918 (1981): Enforceability of Arbitration Awards

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The New York Law Review

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52 N.Y.2d 918 (1981)

When parties voluntarily submit an issue to arbitration, the resulting award should be confirmed if the issue resolved was the one tendered and the resolution is not wholly irrational.

Summary

This case addresses the judicial review of arbitration awards in the context of a collective bargaining agreement. The Central Square Teachers Association filed a grievance alleging that the Board of Education violated the agreement by assigning teachers to cafeteria duty. The arbitrator ruled in favor of the teachers. The Board sought to overturn the award, but the New York Court of Appeals affirmed the lower court’s decision to uphold the arbitrator’s ruling. The court emphasized that as the arbitrator resolved the issue submitted by the parties and the resolution was not irrational, judicial intervention was unwarranted.

Facts

The Central Square Teachers Association filed a grievance against the Board of Education, claiming that assigning junior high school teachers to cafeteria duty violated specific articles of their collective bargaining agreement.

The collective bargaining agreement contained Article II (subd G) or Article XXVII (subd A) which were the articles in question.

The parties submitted the grievance to arbitration.

Procedural History

The arbitrator ruled in favor of the Teachers Association, upholding the grievance.

The Board of Education appealed the arbitrator’s decision.

The Appellate Division affirmed the lower court’s decision to uphold the arbitration award.

The Board of Education appealed to the New York Court of Appeals.

Issue(s)

Whether a court can overturn an arbitration award when the arbitrator resolved the issue submitted by the parties and the resolution is not wholly irrational.

Holding

No, because the arbitrator resolved the precise issue submitted by the parties, and the resolution was not wholly irrational, there is no reason for judicial intervention.

Court’s Reasoning

The Court of Appeals emphasized the limited scope of judicial review of arbitration awards. It stated that if the issue resolved by the arbitrator was indeed the issue submitted by the parties, and the resolution was not

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