Cumberland Teachers Ass'n v. Cumberland School Committee
45 A.3d 1188
| R.I. | 2012Background
- Cumberland Teachers Association and Cumberland School Committee negotiated a three-year CBA for 2006-2009 with a plan to move from a twelve-step to a ten-step salary schedule.
- The parties agreed to transition incrementally: 2006-2007 would be eleven steps, 2007-2008 and 2008-2009 would be ten steps.
- Salaries were below state average; the union sought higher raises and a faster transition, while the district aimed to control costs.
- In September 2007, a dispute over the 2007-2008 transition triggered a grievance and referral to arbitration.
- On December 22, 2008, the arbitrator denied the union’s grievances for 2007-2008 and 2008-2009; the union moved to vacate, and the district moved to confirm.
- The Superior Court denied vacatur and confirmed the award; the union timely appealed to the Rhode Island Supreme Court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the arbitrator manifestly disregarded Article 5.C. | Union argues the arbitrator ignored Article 5.C. | School Committee asserts the arbitrator’s decision drew from the contract and was plausible. | No manifest disregard; award drawn essence of contract; affirmed. |
| Whether there was a mutually agreed transitional plan for the 2007-2008 year. | Union contends there was a written, agreed transitional plan. | Committee contends no agreed, written transition; arbitrator found ambiguity. | Arbitrator’s view that transitional rules were not embodied in writing is reasonable; affirmed. |
Key Cases Cited
- City of East Providence v. International Association of Firefighters Local 850, 982 A.2d 1281 (R.I.2009) (arbitration review limited; award must draw from contract)
- North Providence School Committee v. North Providence Federation of Teachers, Local 920, AFT, 945 A.2d 339 (R.I.2008) (public policy favors finality of arbitration; narrow scrutiny)
- Purvis Systems, Inc. v. American Systems Corp., 788 A.2d 1112 (R.I.2002) (award must be within arbitrator’s authority; irrational or manifestly disregard law grounds)
- Turco v. Town of Coventry, 574 A.2d 143 (R.I.1990) (awards must draw essence from contract and be passably plausible)
- Jacinto v. Egan, 120 R.I. 907, 391 A.2d 1173 (R.I.1978) (arbitration review limits; essence and plausibility standard)