Buffalo United Charter School v. New York State Public Employment Relations Board
Petitioners, consisting of Buffalo United Charter School, Brooklyn Excelsior Charter School, and National Heritage Academies, Inc., initiated a CPLR article 78 proceeding to challenge and annul a February 14, 2011 decision by the New York Public Employment Relations Board (PERB). The PERB decision asserted jurisdiction over the charter schools, rejected National Labor Relations Act (NLRA) preemption claims, and determined that assistant principals were neither managerial nor confidential employees. Petitioners contended that PERB lacked jurisdiction due to its joint public-private employment doctrine, that the NLRA preempted PERB's authority, and that PERB erroneously found the assistant principals lacked managerial or confidential status. They also argued the PERB decision unconstitutionally impaired their contractual rights. The court largely upheld PERB's jurisdiction, ruling that the Charter Schools Act superseded PERB's joint public-private employment doctrine and denying the NLRA preemption claim. However, the court annulled PERB's determination regarding the managerial and confidential status of assistant principals at Brooklyn Excelsior Charter School, reinstating the Administrative Law Judge's original finding on that specific issue.