Matter of Board of Educ. v. Watertown Educ. Assn., 74 N.Y.2d 912 (1989): Arbitrability of Teacher Grievances and Public Policy

74 N.Y.2d 912 (1989)

A dispute over the interpretation of a collective bargaining agreement, including its applicability to a specific grievance, is arbitrable on its face, and a stay of arbitration is premature unless the potential remedy would violate public policy.

Summary

This case addresses whether a school district should be granted a stay of arbitration regarding a teacher’s grievance. The Watertown Education Association sought arbitration, claiming the school district violated the collective bargaining agreement by altering a teacher’s class composition based on parental complaints. The school district argued the agreement didn’t apply and that class composition was a nondelegable duty, making arbitration against public policy. The Court of Appeals reversed the lower courts’ decision to stay arbitration, holding that the dispute was arbitrable and that a public policy objection was premature because a permissible remedy was possible.

Facts

A teacher’s class composition was altered by the school district, partly based on parental complaints. The Watertown Education Association (the union) contended this violated Article IV, Section 2 of their collective bargaining agreement. This section stipulated that when a parental complaint arose, the principal had to arrange a meeting between the parents and teacher to foster constructive discussion. The union sought arbitration to resolve this dispute.

Procedural History

The school district sought a stay of arbitration in the lower courts. The lower courts granted the stay. The Court of Appeals reversed the lower courts’ orders, dismissing the petition to stay arbitration.

Issue(s)

Whether the dispute over the applicability of Article IV, Section 2 of the collective bargaining agreement to the school district’s alteration of a teacher’s class composition is arbitrable.

Holding

Yes, because the collective bargaining agreement provides for arbitration of any dispute concerning its proper interpretation, and a public policy objection is premature if the arbitrator could fashion a remedy that does not violate public policy.

Court’s Reasoning

The Court reasoned that the collective bargaining agreement explicitly provided for arbitration of disputes regarding its interpretation. Therefore, on its face, the dispute over whether Article IV, Section 2 applied to the situation was arbitrable. The Court then addressed the school district’s argument that submitting the dispute to arbitration would violate public policy, which asserts that determining class composition is the school district’s nondelegable duty. The Court rejected this argument as premature. It stated that a stay of arbitration is unwarranted