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Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

Lahendro v. New York State United Teachers Ass'n

Plaintiff Michael F. Lahendro, a guidance counselor, sued the New York State United Teachers Association (NYSUT) and Brushton-Moira Teachers Association for breach of the duty of fair representation and negligence after NYSUT failed to timely file a demand for a hearing against his employment termination. This oversight led Lahendro to accept a settlement including retirement. Defendants moved to dismiss the lawsuit, which the Supreme Court denied, leading to this appeal. The appellate court reversed, dismissing the breach of fair representation claim based on the 'Martin v Curran' rule, which requires proving all individual union members authorized or ratified the conduct for suits against unincorporated associations, which plaintiffs could not do. Additionally, the negligence claim was dismissed as actions against unions for duties under collective bargaining agreements must be for breach of fair representation.

Breach of Duty of Fair RepresentationNegligenceUnincorporated AssociationMartin v Curran RuleEducation LawCPLRLate FilingSettlement AgreementEmployment TerminationGuidance Counselor
References
24
Case No. MISSING
Regular Panel Decision

United Federation of Teachers, Local 2 v. Board of Education

The United Federation of Teachers appealed a decision by the Board of Education of the City of New York regarding the selection of teachers for an after-school program. An arbitrator previously ruled that the Board's selection process for Linda Feil, a qualified teacher, was arbitrary and capricious, ordering her placement and back pay. While the Supreme Court confirmed this arbitration award, the Appellate Division reversed, arguing public policy violations and the arbitrator exceeding authority. The Court of Appeals reversed the Appellate Division's decision, finding that the arbitration award neither violated public policy nor exceeded the arbitrator's powers under the collective bargaining agreement. Consequently, the Court of Appeals reinstated the Supreme Court's order confirming the arbitration award in favor of the teacher.

ArbitrationCollective BargainingPublic Policy ExceptionArbitrator AuthorityTeacher EmploymentGrievance ProcedureJudicial ReviewEducational StandardsArbitrary and CapriciousSeniority
References
17
Case No. MISSING
Regular Panel Decision

Board of Education v. West Hempstead Chapter Branch II of New York State Teachers Ass'n

The plaintiff school board sued to enjoin the defendant teachers association from issuing news releases and making public statements, arguing they violated their agreement and that grievance procedures should be used. The court denied the school board's motion for a temporary restraining order and granted the teachers association's cross-motion to dismiss the complaint. The court reasoned that the grievance procedure outlined in the agreement was designed for individual employee problems, not broad issues like those raised by the association's demands for resignations. Furthermore, the court emphasized that enjoining speech constituted an impermissible prior restraint, only justified in the narrowest exceptions, which were not met in this case.

Collective BargainingGrievance ProcedureFreedom of SpeechPrior RestraintPublic EmployeesTeachers UnionLabor DisputeInjunctionDismissal of ComplaintCross-Motion
References
9
Case No. MISSING
Regular Panel Decision

Board of Education of Yorktown Central School District v. Yorktown Congress of Teachers

The Yorktown Congress of Teachers (YCT) appealed an order from the Supreme Court, Westchester County, which had granted the Board of Education of the Yorktown Central School District's (Board) petition to stay arbitration and denied the YCT's cross-petition to compel arbitration. The dispute stemmed from the Board's refusal to approve certain graduate credits for compensation for a teacher, leading the YCT to file a grievance and demand arbitration under their collective bargaining agreement (CBA). The Supreme Court's order was reversed on appeal. The appellate court found no public policy or statutory prohibition against arbitration and determined that the dispute reasonably related to the CBA's subject matter. Consequently, the Board's petition to stay arbitration was denied, and the YCT's cross-petition to compel arbitration was granted, directing the parties to proceed to arbitration.

Collective Bargaining AgreementArbitrationGraduate CreditsTeacher CompensationGrievance ProcedureAppellate ReviewPublic Sector EmploymentEducation LawCPLR Article 75Contract Interpretation
References
14
Case No. 2022 NY Slip Op 04680
Regular Panel Decision
Jul 21, 2022

Matter of Buffalo Teachers Fedn., Inc. v. New York State Pub. Empl. Relations Bd.

This case concerns an Article 78 proceeding initiated by the Buffalo Teachers Federation, Inc. to challenge a determination by the New York State Public Employment Relations Board (PERB). PERB found that the Federation engaged in an unlawful strike in violation of Civil Service Law § 210 (1) after 16 teachers from Public School 59 called in sick following a threatening incident. The Appellate Division, Third Department, confirmed PERB's determination, concluding that there was substantial evidence to support the finding that the Federation, through its agent, instigated and condoned a concerted work stoppage. The court dismissed the Federation's petition.

Unlawful StrikePublic Employment RelationsTeacher UnionTaylor LawConcerted Work StoppageSchool District DisputeAdministrative ReviewLabor Law ViolationCollective Bargaining UnitSubstantial Evidence Review
References
6
Case No. MISSING
Regular Panel Decision

Reich v. Federation of Catholic Teachers, Inc.

The Secretary of Labor initiated an action to set aside the March 1993 election of the Federation of Catholic Teachers' officers and council members, alleging violations of Title IV of the Labor-Management Reporting and Disclosure Act (LMRDA). The Secretary contended the election was unfair due to the official ballot promoting incumbents as "The Action Team" while listing challengers simply as "The Opposition," and improper involvement of the incumbent president, Margaret Menard, in the election process. The court found the ballot unfair, constituting a violation of 29 U.S.C. § 481(c), ruling that the incumbent slate designation "The Action Team" without a corresponding name for the opposition slate was a violation, regardless of intent. Given the close election margins, the court determined that this violation may have affected the outcome and ordered a new election under the Secretary's supervision. While the court dismissed the claim of improper involvement by Menard, it noted the election's excessive informality and casual attitude towards legal requirements, instructing future elections to ensure committee independence and adherence to Department of Labor guidelines.

Labor-Management Reporting and Disclosure ActLMRDA Title IVUnion ElectionElection ViolationUnfair BallotIncumbent SlateOpposition SlateExhaustion of RemediesPrima Facie CaseBurden of Proof
References
5
Case No. MISSING
Regular Panel Decision
Feb 22, 1982

In re the Arbitration between Board of Education of Connetquot Central School District & Connetquot Teachers Ass'n

This dissenting opinion argues for affirming a Special Term's order directing a board of education to arbitrate a grievance filed by a teachers union. The union's claim involves continued use of office space in school district buildings, citing a collective bargaining agreement and past practice. The dissent contends that the arbitration clause is broad and encompasses the dispute, rejecting the employer's argument that law or public policy (specifically Education Law § 414 or Civil Service Law § 209-a) prohibits arbitration of this grievance. Justice O'Connor asserts that the union's use of office space for its statutory duties as a collective bargaining agent serves a "school purpose," similar to administrative and support services, and thus is not excluded by Education Law § 414. The dissent concludes that the order compelling arbitration should be affirmed.

ArbitrationCollective Bargaining AgreementGrievanceTeachers UnionBoard of EducationOffice SpaceSchool PropertyEducation LawCivil Service LawPublic Employment Relations Board
References
15
Case No. MISSING
Regular Panel Decision
Apr 03, 2006

Lawrence Teachers Ass'n v. Lawrence Public Schools

This case concerns an appeal by the Lawrence Teachers Association (petitioner) challenging the denial of their petition to confirm an arbitration award. The arbitration award mandated Lawrence Public Schools (respondent) to designate members of the petitioner’s bargaining unit to provide special education services outside the school district's geographical boundaries. The Supreme Court, Nassau County, denied the petition, concluding the award was unenforceable. The appellate court affirmed this decision, ruling that the arbitration award violated public policy as it contravened Education Law former § 3602-c (2). This statute required the school district to contract with the school district where the nonpublic school attended by the pupil was located for such services. The court emphasized that an arbitrator's award cannot stand if it is contrary to well-defined statutory law and public policy.

Arbitration AwardPublic PolicyEducation LawSpecial Education ServicesCollective BargainingStipulationStatutory ViolationAppellate ReviewSchool District ObligationsLabor Dispute
References
4
Case No. MISSING
Regular Panel Decision

Crystal v. Board of Education

The Long Beach Classroom Teachers Association initiated a CPLR article 78 proceeding on behalf of six school nurse teachers and one dental hygiene teacher whose tenured positions were abolished by the respondent in May 1975 due to budgetary constraints. The petitioner contended that the 'vertical' tenure classification was unconstitutional, arguing for a 'horizontal' classification that would protect the named teachers by displacing less senior general academic teachers. However, the court ruled that the petitioner lacked standing to sue, as the rights were personal to the individual teachers who had not formally joined the proceeding or filed claims. Furthermore, the court identified a potential conflict of interest, as granting the requested relief would adversely affect current members of the association. Consequently, the court dismissed the petition, finding that the individual teachers' failure to assert their own rights left no alternative.

Tenure rightsStanding to sueCPLR Article 78Teacher terminationVertical tenureHorizontal tenureBudgetary economiesSchool nurse teacherDental hygiene teacherIndispensable parties
References
8
Case No. MISSING
Regular Panel Decision
Jun 24, 2005

Mineola Union Free School District v. Mineola Teachers' Ass'n.

The petitioner, Mineóla Union Free School District, appealed an order from the Supreme Court, Nassau County, which had denied its motion to stay arbitration and granted the Mineóla Teachers’ Association's cross-motion to compel arbitration. The appellate court affirmed the lower court's decision, ruling that the dispute, related to article 24 of the collective bargaining agreement, was indeed subject to arbitration. The court rejected the District's argument that an arbitration award favoring the Association would violate public policy, emphasizing the narrow scope of the public policy exception in public employment cases. It concluded that no law prohibited such an award and that upholding article 24 would not force the District to hire unqualified candidates, thus not violating Education Law §§ 3012 (1) (a) and 1709 (16).

ArbitrationCollective BargainingPublic EmploymentTaylor LawPublic Policy ExceptionEducation LawAppealNassau CountySchool DistrictTeachers Union
References
7
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