Griggsville-Perry Community Unit School District No. 4 v. Illinois Educational Labor Relations Board
2013 IL 113721
| Ill. | 2013Background
- Hires, a paraprofessional, was discharged from Griggsville-Perry CUSD No. 4 in March 2008 after 11 years of service.
- Allegations centered on her demeanor toward students and alleged but unverified complaints; district relied on a private notebook of the principal as well as three official notes.
- Union grievance challenged lack of specificity, failure to notify, lack of opportunity to respond, and inadequate warning before dismissal.
- Arbitrator found district violated section 2.6 of the CBA by failing to provide a meaningful hearing and ordered reinstatement.
- Appellate court reversed IELRB; Illinois Supreme Court reversed the appellate court and affirmed IELRB and the arbitrator’s award.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the arbitrator acted within his authority | Union argues arbitrator drew essence from the CBA | District contends arbitrator exceeded authority by personal policy for dismissal | Yes, arbitrator drew essence from the CBA |
| Whether the arbitrator correctly applied section 2.6 | Union asserts District violated 2.6 by improper notice/hearing | District argues 2.6 was satisfied | Arbitrator's interpretation of 2.6 was within his remit; compelled compliance |
| Whether Harrisburg limits reading of just cause or arbitrary standard | Union relies on Harrisburg to support meaningful process; no just cause read in | District argues Harrisburg bars imposing new standard not in contract | Arbitrator properly applied arbitrariness standard consistent with bargaining history |
Key Cases Cited
- AFSCME v. State, County & Municipal Employees, 124 Ill. 2d 246 (1988) (extremely limited judicial review of arbitral awards; essence test for contract interpretation)
- Misco, Inc. v. United Paperworkers, 484 U.S. 29 (1987) (arbitrator’s view of contract binding; courts won’t reweigh merits)
- United Steelworkers v. Enterprise Wheel & Car Corp., 363 U.S. 564 (1960) (arbitrators must interpret the contract, not impose own justice)
- Stolt-Nielsen S.A. v. AnimalFeeds International Corp., 559 U.S. 548 (2010) (high hurdle to show arbitrator acted outside contract; must infer noncontractual basis if necessary)
- Board of Education of Harrisburg Community Unit School District No. 3 v. Illinois Educational Labor Relations Board, 227 Ill. App. 3d 208 (1992) (arbitrator cannot read just cause into contract when not adopted; due process limits but not read limits)