Bound Brook Board of Education v. Glenn Ciripompa (076905), 153 A.3d 931

Glenn Ciripompa, a tenured high-school math teacher, was charged by the Bound Brook Board of Education with two counts of conduct unbecoming under the Tenure Employees Hearing Law (TEHL).
Count I alleged misuse of District-issued electronics (laptop and iPad) to send, receive, and store nude/sexually explicit material; evidence from the devices supported this count.
Count II alleged unprofessional and inappropriate conduct toward female staff (propositions made in front of students, comments about appearance, using students to deliver flowers/messages), citing a district policy against inappropriate staff conduct.
The Commissioner agreed the charges warranted termination and referred the matter to an arbitrator; the arbitrator sustained Count I but dismissed Count II after applying the Lehmann hostile-work-environment sexual-harassment standard, reducing the penalty to a 120-day unpaid suspension.
The Board challenged the Count II ruling; the Chancery Division vacated the award, the Appellate Division reinstated it, and the New Jersey Supreme Court granted certification to decide whether the arbitrator exceeded his authority by importing the Lehmann standard.

Issue	Plaintiff's Argument (Board)	Defendant's Argument (Ciripompa)	Held
Whether the arbitrator exceeded his authority by treating Count II (unbecoming conduct) as a LAD sexual‑harassment hostile‑work‑environment claim and applying Lehmann	The arbitrator improperly recharacterized the charge, imposing a Lehmann "severe or pervasive" standard that the Board did not pled or prove; unbecoming conduct has a distinct, broader standard focused on morale, efficiency, and public perception	Count II's allegations and the Board's references to harassment policies show the true nature of the charge was sexual harassment, so applying Lehmann was appropriate	Reversed the Appellate Division: arbitrator exceeded authority by converting Count II into a Lehmann claim; remanded for new arbitration to decide unbecoming conduct under the proper standard

Lehmann v. Toys ‘R’ Us, Inc., 132 N.J. 587 (establishes the four‑prong hostile‑work‑environment sexual‑harassment test under the LAD)
Grover v. Universal Underwriters Ins. Co., 80 N.J. 221 (arbitral awards must be consonant with the matter submitted)
Metromedia Energy, Inc. v. Enserch Energy Servs., 409 F.3d 574 (3d Cir.) (standard for reviewing whether arbitrators exceeded scope of parties’ submissions)
Karins v. Atlantic City, 152 N.J. 532 (unbecoming conduct can be found without proving harassment; focuses on morale and public confidence)
In re Young, 202 N.J. 50 (school‑employment unbecoming‑conduct standard can sustain discipline even where other fora found allegations unfounded)