Craig Sacco v. Cranston School Department Charles Pearson v. Cranston School Department
53 A.3d 147
R.I.2012Background
- Sacco and Pearson are Cranston West teachers who also served as head coaches (Sacco: varsity boys’ hockey for nine years; Pearson: varsity girls’ soccer for seven years).
- After the 2007–2008 season both received unfavorable evaluations; Pearson was placed on probation for one year, and Sacco was removed from coaching.
- The coaches/grievants filed grievances under Article VI of the CBA (effective 2005–2008) seeking arbitration of their coaching-related actions.
- The school department asserted the CBA did not apply to coaching positions because coaches operate under separate one-year coaching contracts, governed by Resolution No. 05-6-29.
- The trial court granted summary judgment in favor of the school department, and the Rhode Island Supreme Court affirmed, holding that coaching positions are not encompassed within the CBA’s professional-teacher grievance/arbitration rights.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Are coaches covered by the CBA grievance/arbitration rights? | Sacco: coaches have CBA rights. | Cranston School Dept: coaches are outside the CBA. | Not arbitrable; coaches not within the CBA. |
| Does Article VI A.1 define grievances to include coaching disputes? | Sacco: grievances extend to coaching actions under Article VI. | Cranston: Article VI covers teachers, not coaches. | Coaching disputes are not within Article VI’s scope. |
| What effect does Resolution No. 05-6-29 have on coaching contracts and arbitration rights? | CBA rights apply to coaches despite Resolution 05-6-29. | Resolution 05-6-29 governs coaching contracts and excludes arbitration rights. | Resolution 05-6-29 creates separate one-year contracts with no arbitration rights. |
| Does the CBA, including Article XXIV, confer coaching arbitration rights? | CBA provisions for extracurriculars imply arbitration rights for coaches who are teachers. | CBA’s extracurricular provisions do not grant arbitration rights to coaches. | No implied or express grant; Article XXIV/Appendix D not applicable to arbitration for coaches. |
Key Cases Cited
- Harbor Creek School District v. Harbor Creek Education Association, 640 A.2d 899 (Pa. 1994) (extracurricular work by teachers is non-professional and not arbitrable)
- School Committee of North Kingstown v. Crouch, 808 A.2d 1074 (R.I. 2002) (arbitrability is a matter of contract; review de novo)
- AT&T Technologies, Inc. v. Communications Workers of America, 475 U.S. 643 (1986) (clear language required to compel arbitration)
- Moore v. Rhode Island Board of Governors for Higher Education, 18 A.3d 541 (R.I. 2011) (standard of review for summary judgment; de novo on arbitral issues)
- Matter of Riverhead Central School District v. Riverhead Central Faculty Association, 528 N.Y.S.2d 611 (N.Y. App. Div. 1988) (negative evaluation of coaching position subject to arbitration in some jurisdictions)