Central Westmoreland Career & Technology Center Education Ass'n, PSEA/NEA v. Penn-Trafford School District, 131 A.3d 971

Central Westmoreland Career & Technology Center (Vocational School) historically taught math to vocational students from sending districts; in 2010 eight districts decided to provide that math at their home high schools instead.
The Vocational School curtailed math offerings and suspended five certified math teachers; it created a pool of suspended teachers and sent their names to Penn-Trafford per 24 P.S. § 11-1113(b.1).
Penn-Trafford accommodated the vocational students in existing math classes (no new classes were added). A separate vacancy arose when a Penn-Trafford teacher resigned; Penn-Trafford filled that vacancy without hiring from the Vocational School’s pool.
The Vocational School teachers and their union sued, seeking a declaration that § 11-1113(b.1) required Penn-Trafford to hire from the pool and recovery of lost wages.
The county court and a Commonwealth Court panel ruled for Penn-Trafford, holding no "transfer as a unit" of a class or program occurred; the Supreme Court granted review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 11-1113(b.1) requires receiving schools to hire from a furloughed-teacher pool when they assume program responsibility for transferred students even if no class/program was transferred as a unit	§ 11-1113(b.1) gives pool members hiring priority whenever a school "assumes program responsibility for transferred students," regardless of whether a class/program was transferred as a unit	The Transfer Act requires an actual transfer of a class/program as a unit to trigger protections; (b.1) supplements (a) and does not eliminate the "transfer as a unit" requirement	The Court held (b.1) is broader: assumption of program responsibility for transferred students (including student transfers into existing classes) triggers (b.1) hiring priority

Hahn v. Marple Newtown Sch. Dist., 571 A.2d 1115 (Pa. Cmwlth. 1990) (defined "transfer" as carrying/taking from one place to another and tied protections to a program/class recreated elsewhere)
Allegheny Intermediate Unit #3 Educ. Ass'n v. N. Hills Sch. Dist., 624 A.2d 802 (Pa. Cmwlth. 1993) (explained (b.1) was added to protect employees of entities like vocational schools as programs shifted to districts)
Cook v. Chambersburg Area Sch. Dist., 97 A.3d 419 (Pa. Cmwlth. 2014) (reaffirmed Hahn's ‘‘transfer as a unit’’ understanding; dissent argued broader reading of (b.1))
Commonwealth v. Elliott, 50 A.3d 1284 (Pa. 2012) (statutory-drafting principle that different words/phrases carry different meanings)