Commonwealth, Department of Corrections, State Correctional Institution at Forest v. Pennsylvania State Corrections Officers Ass'n, 173 A.3d 854

Barry Robinson (Grievant) was a corrections officer at SCI‑Forest serving as a Maintenance Rover supervising inmate workers who unloaded deliveries.
Video and subsequent searches (Oct. 30, 2015; Jan. 6–9, 2016) showed unauthorized food, magazines, pornography, and other items in the maintenance annex; video showed Grievant handling delivery items and tossing a box to an inmate.
Grievant admitted taking food from trucks to feed crews who missed lunch and said he recovered missing hot sauce and disciplined the inmate who took it.
The Department conducted pre‑disciplinary conferences and discharged Grievant on April 8, 2016; Grievant had previously been awarded a tower observation post but was discharged before starting.
An arbitrator reinstated Grievant with a 30‑day suspension but stated Grievant "should not be in a position which requires his supervision of inmates," and suggested placement in a tower position.
The Department appealed; the Commonwealth Court vacated the arbitrator’s award as not drawing its essence from the collective bargaining agreement because the restriction on supervising inmates conflicted with the statutory definition of a corrections officer and the employer’s managerial rights.

Issue	Plaintiff's Argument (Department)	Defendant's Argument (Association)	Held
Whether the arbitrator’s reduction of discharge to suspension/reinstatement is permissible under the essence test	Award improperly modified managerial rights and created a class of officers unable to perform core duties; thus not rationally derived from CBA	Arbitrator may reduce discharge to reinstatement under undefined "just cause"; award left employer flexibility and did not bar all inmate supervision	Reduction to suspension alone is not per se improper, but here award failed essence test because it restricted supervisory capacity inconsistent with statutory role and managerial rights
Whether the arbitrator’s restriction (no supervision of inmates) lawfully binds the Department’s workforce assignments	Restriction interferes with employer’s Article 2 managerial rights and unduly burdens prison operations	Award did not prevent reassigning Grievant to other CO posts (e.g., tower) and did not eliminate duties of care/custody	Restriction impermissibly infringed managerial rights and conflicted with the statutory definition of a corrections officer; vacated
Whether public policy (inmate safety/Eighth Amendment) requires vacatur	Award could risk inability to protect inmates and create liability	Award did not require employing an officer incapable of supervision	Court did not resolve public policy claim because it vacated on essence grounds

State Sys. of Higher Educ. (Cheyney Univ.) v. State Coll. Univ. Prof’l Ass’n (PSEA‑NEA), 743 A.2d 405 (Pa. 1999) (arbitrator must draw essence from CBA)
Office of Attorney Gen. v. Council 13, AFSCME, 844 A.2d 1217 (Pa. 2004) (arbitrator may interpret undefined "just cause" and reinstate despite finding misconduct)
Westmoreland Intermediate Unit #7 v. Westmoreland Intermediate Unit #7 Classroom Assistants Educ. Support Pers. Ass’n, 939 A.2d 855 (Pa. 2007) (essence test articulated)
Northumberland County Comm’rs v. AFSCME Local 2016, 71 A.3d 367 (Pa. Cmwlth. 2013) (arbitral deference noted)
Philadelphia Hous. Auth. v. AFSCME Dist. Council 33, Local 934, 52 A.3d 1117 (Pa. 2012) (public policy exception to arbitral awards is a question of law)
City of Bradford v. Teamsters Local Union No. 110, 25 A.3d 408 (Pa. Cmwlth. 2011) (public policy can justify vacatur of an arbitration award)