Jay Classroom Teachers Association v. Jay School Corporation and Indiana Education Employment Relations Board, 2016 Ind. LEXIS 521

2011 amendments to Indiana teacher collective-bargaining law shortened mediation/factfinding, introduced last-best-offers (LBOs), and required factfinders to impose one party’s LBO as the CBA limited to wages, salaries, and related fringe benefits.
Jay Classroom Teachers Ass’n (Association) and Jay School Corp. (School) reached impasse for 2013–2014; exchanged LBOs; factfinder adopted the School’s LBO.
The disputed provision allowed a superintendent to place teachers hired after the school year began ‘‘on any line of the scale as determined by the Superintendent,’’ with that placement fixed for the contract year.
IEERB affirmed the factfinder, construing the provision as tied to the existing bargained salary scale and noting statutory checks (e.g., prohibition on deficit financing).
Trial court affirmed IEERB; Court of Appeals reversed, holding the provision impermissibly conflicted with the Association’s statutory right to bargain salaries. Supreme Court granted transfer to decide whether IEERB reasonably concluded the provision was lawful.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a contract provision permitting the superintendent to place mid‑year hires "on any line" of the salary scale conflicts with teachers’ statutory right to collectively bargain salaries	The provision vests unilateral, unfettered discretion in the superintendent, defeating the Association’s statutory right to bargain salaries.	The provision was part of a bargained-for LBO, ties placement to the established bargained salary scale, and is constrained by the statutory prohibition on deficit financing.	Court held IEERB reasonably concluded the provision is lawful: it was collectively bargained and superintendent’s discretion was limited by the bargained scale and deficit-financing restrictions.

State Bd. of Registration for Prof'l Eng’rs v. Eberenz, 723 N.E.2d 422 (Ind. 2000) (courts defer to agency factual findings; do not retry facts de novo)
Ind. Dep’t of Envtl. Mgmt. v. Conard, 614 N.E.2d 916 (Ind. 1993) (agency factfinding deference)
Ind. Dep’t of Envtl. Mgmt. v. West, 838 N.E.2d 408 (Ind. 2005) (substantial-evidence standard; defer to agency findings supported by evidence)
Nat. Res. Def. Council v. Poet Biorefining-N. Manchester, LLC, 15 N.E.3d 555 (Ind. 2014) (agency legal conclusions reviewed de novo but given great weight if reasonable)
Chrysler Grp., LLC v. Review Bd. of Ind. Dep’t of Workforce Dev., 960 N.E.2d 118 (Ind. 2012) (agency interpretations entitled to deference where reasonable)
Sullivan v. Day, 681 N.E.2d 713 (Ind. 1997) (agency interpretations may prevail even against other reasonable readings)
Jay Classroom Teachers Ass’n v. Jay Sch. Corp., 45 N.E.3d 1217 (Ind. Ct. App. 2015) (Court of Appeals decision reversing trial court on the salary-flexibility provision)
Ind. Educ. Emp’t Relations Bd. v. Nettle Creek Classroom Teachers Ass’n, 26 N.E.3d 47 (Ind. Ct. App. 2015) (related holding on permissibility of additional compensation provisions)