Plainedge Federation of Teachers v. Plainedge Union Free School District, 58 N.Y.2d 902 (1983)
When a collective bargaining agreement provides for advisory arbitration, a school district’s determination based on the arbitrator’s recommendation should be reviewed under the arbitrary and capricious standard applicable to Article 78 proceedings, unless the parties’ conduct converts the arbitration to a binding determination.
Summary
This case concerns a dispute over whether a substitute teacher was covered by a collective bargaining agreement and entitled to sick leave benefits. The dispute went to advisory arbitration, where the arbitrator found the teacher was not covered. The school district adopted this decision. The teachers’ union challenged the district’s action in an Article 78 proceeding. The Court of Appeals held that because the bargaining agreement expressly provided for advisory arbitration and the parties’ conduct did not convert it to binding arbitration, the school district’s determination should be reviewed to see if it was arbitrary or capricious. The Court found it was not.
Facts
Sharon Licht, a permanent substitute teacher, claimed she was covered by the collective bargaining agreement between the Plainedge Federation of Teachers and the Plainedge Union Free School District. Licht sought full sick leave benefits under the agreement. The school district denied her claim. The collective bargaining agreement’s grievance procedure led to advisory arbitration.
Procedural History
The arbitrator concluded Licht was not covered by the agreement, and the school district adopted the arbitrator’s decision. The Plainedge Federation of Teachers brought an Article 78 proceeding challenging the district’s action. Special Term vacated the determination. The Appellate Division reversed and dismissed the petition, finding the parties’ conduct had converted the advisory arbitration to binding arbitration and that the arbitrator’s award was not irrational. The Court of Appeals affirmed the Appellate Division’s order, but on a different rationale.
Issue(s)
- Whether the arbitrator’s award was advisory or binding.
- If the arbitrator’s award was advisory, whether the school district’s determination was arbitrary or capricious and should be overturned.
Holding
- No, because the collective bargaining agreement expressly provided that arbitration awards were advisory only, and the parties’ conduct did not convert it to a binding determination.
- No, because the school district’s determination was based on the recommendations of the arbitrator, as allowed for in the agreement, and had support in both the plain terms of the agreement and the prior bargaining history.
Court’s Reasoning
The Court of Appeals found that the Appellate Division erred in finding that the arbitration had become binding. The Court emphasized that the collective bargaining agreement expressly provided that arbitration awards were advisory only. Submitting the issue of the agreement’s coverage to the arbitrator was insufficient to convert the arbitration to binding. The Court distinguished this case from others where the parties stipulated the remedy to be implemented or granted the arbitrator powers beyond those in the collective bargaining agreement.
The Court then applied the standard of review applicable to Article 78 proceedings to the school district’s determination. Under this standard, the Court held that the district’s determination was not arbitrary or capricious. The determination was based in large part on “careful consideration [of] the recommendations of the Arbitrator” in accordance with the agreement of the parties. The determination also found support in the plain terms of the agreement and in the prior bargaining history between the district and union. Therefore, the Court upheld the school district’s determination. The court emphasized the importance of adhering to the explicit terms of the collective bargaining agreement regarding the nature of arbitration (advisory vs. binding) and the appropriate standard of review.