Board of Education of Peoria School District No. 150 v. Peoria Federation of Support Staff
972 N.E.2d 1254
Ill. App. Ct.2012Background
- Board of Education of Peoria School District No. 150 directly employs police officers (26 officers) who have been represented by Educational Labor Relations Board bargaining units since 1989; the most recent agreement expired June 30, 2010.
- Public Act No. 96-1257 (effective July 23, 2010) amended the Illinois Public Labor Relations Act to classify school-district peace officers as public employees, expanding the Act’s scope and IL Labor Relations Board jurisdiction.
- Plaintiff contends the Act is unconstitutional special legislation and that Educational Labor Relations Board retains exclusive jurisdiction over disputes with Unit No. 114.
- In March 2011, plaintiff sued Unit No. 114 and the two labor boards, seeking declaration of unconstitutionality and exclusive-jurisdiction relief.
- Labor boards moved to dismiss; trial court granted dismissal; appellate court reversed and remanded, holding the complaint stated actionable claims and exhaustion issues were properly addressed as jurisdictional challenges.
- The court discusses whether the Act applies to the parties and whether the sum of distinctions created by the Act is rational and not arbitrary.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is Public Act 96-1257 unconstitutional special legislation? | Peoria argues the Act arbitrarily benefits Unit No. 114. | Boards claim the Act’s classifications are rationally related to state interests. | Yes, claims survive; distinctions are arbitrary; remand on constitutionality. |
| Does the Act apply to plaintiff and Unit No. 114, giving IL Labor Relations Board jurisdiction? | Act applies and Educational Labor Relations Board loses exclusive jurisdiction. | Act alters jurisdiction in favor of IL Labor Relations Board. | Claims survive; Act’s applicability and jurisdiction are unresolved; remand. |
| Must plaintiff exhaust administrative remedies before challenging jurisdiction? | Exhaustion not required for jurisdictional challenge. | Exhaustion required prior to challenges to agency jurisdiction. | Exception to exhaustion applies; court can address jurisdictional challenge; remand. |
Key Cases Cited
- State of Illinois Dept. of Central Management Services v. State Labor Relations Board, State Panel, 373 Ill. App. 3d 242 (2007) (explains interest-arbitration shift as economic weapon in bargaining)
- County of Kane v. Carlson, 116 Ill. 2d 186 (1987) (exemption from exhaustion for facial constitutional challenges to statute)
- Lake County v. Illinois Human Rights Comm’n, 200 Ill. App. 3d 149 (1990) (exhaustion exception for jurisdictional challenges; no need to exhaust where agency lacks jurisdiction)
- Nestle USA, Inc. v. Dunlap, 365 Ill. App. 3d 727 (2006) (jurisdiction not determined by merits; exhaustion of administrative remedies concerns)
- Elementary School Dist. 159 v. Schiller, 221 Ill. 2d 130 (2006) (illustrates singularly targeted legislation not per se prohibited)