2018 Ohio 2867
Ohio Ct. App.2018Background
- TARTA (defendant/appellant) and ATU Local 697 (plaintiff/appellee) disputed whether their collective-bargaining impasse must proceed to binding interest arbitration under their agreement.
- The trial court denied TARTA’s motions for summary judgment (Oct. 26, 2015 & Aug. 19, 2016) and, after a bench trial, entered judgment (July 31, 2017) ordering binding interest arbitration, finding the labor dispute was related to TARTA’s receipt of federal funding.
- TARTA moved under Civ.R. 52 for separate findings of fact and conclusions of law after the bench trial; the trial court denied that motion (Aug. 30, 2017), stating its July 31 opinion contained the necessary findings.
- TARTA appealed, raising four assignments of error: (1) parties did not agree to binding interest arbitration for successor CBA terms; (2) trial court erred in stating Ohio favors binding interest arbitration; (3) trial court’s judgment is against the manifest weight of the evidence; (4) trial court erred in denying Civ.R. 52 findings.
- The Sixth District focused on the Civ.R. 52 issue, finding the trial court’s July 31 opinion did not set out adequate written findings explaining why the dispute related to federal funding and thus failed the rule’s mandatory requirements when facts were tried to the court.
Issues
| Issue | Plaintiff's Argument (ATU) | Defendant's Argument (TARTA) | Held |
|---|---|---|---|
| 1. Whether parties agreed to submit successor CBA terms to binding interest arbitration | Agreement’s arbitration clause covers disputes tied to federal funding, so arbitration appropriate | No agreement to arbitrate terms of successor CBA; arbitration not compelled | Not reached on merits — rendered moot after disposition on Civ.R. 52 |
| 2. Whether Ohio law favors binding interest arbitration to resolve such impasses | Courts generally favor arbitration; supports compelling arbitration | Court erred in treating preference as dispositive without adequate findings | Not reached on merits — rendered moot |
| 3. Whether the bench-trial judgment is against the manifest weight of the evidence | Trial court correctly found dispute related to federal funding after trial | Trial court failed to make the necessary factual findings to support that conclusion | Not reached on merits — rendered moot |
| 4. Whether trial court erred in denying Civ.R. 52 request for separate findings | Findings unnecessary because issue was purely legal | Court failed to provide separate written findings despite factual dispute and timely request | Held for TARTA: trial court abused discretion / failed Civ.R. 52; judgment reversed and remanded for written findings |
Key Cases Cited
- Werden v. Crawford, 70 Ohio St.2d 122 (1982) (Civ.R. 52 findings mandatory when facts tried by the court)
- State ex rel. Gilbert v. City of Cincinnati, 125 Ohio St.3d 385 (2010) (opinion may be adequate when read with the record to decide legal issues)
- Kroeger v. Ryder, 86 Ohio App.3d 438 (6th Dist. 1993) (findings must allow parties and appellate court to review resolved factual disputes)