Massillon Firefighters IAFF Local 251 v. Massillon
2012 Ohio 4729
Ohio Ct. App.2012Background
- Union and City were bound by a CBA effective 11/14/2005–11/09/2008 regarding grievances and arbitration.
- Sattler grievant challenged City’s sick-leave calculations; arbitrator ruled in Sattler’s favor and ordered ceasing improper deductions.
- Union filed Thieret grievance seeking relief for all members and compliance with the Sattler award.
- Arbitrator held Thieret grievance timely and proceeded to merits; later ruled Thieret not barred by res judicata.
- City sought to vacate the arbitration award in court; Union sought to confirm the award; trial court granted City’s vacatur and denied confirmation.
- Appellate court reversed, holding the trial court erred by vacating the award and affirmed the arbitration award.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the trial court properly vacate the arbitration award? | Massillon argued the arbitrator acted within authority and res judicata did not bar the Thieret grievance. | City argued the awards were barred by res judicata and the court could vacate for legal error. | Yes; trial court erred in vacating the award. |
| Was the second assignment regarding striking affidavits moot? | Union argued affidavits should be struck; contest deemed necessary for ruling. | City contended affidavits supported vacatur. | Moot |
Key Cases Cited
- Findlay City Schools Dist. Bd. of Educ. v. Findlay Edn. Assn., 49 Ohio St.3d 129 (1990) (limits appellate review of arbitration awards)
- Goodyear Tire & Rubber Co. v. Local Union No. 200, 42 Ohio St.2d 516 (1975) (arbitrator final on law and facts; limited judicial review)
- Cty. of Summit v. City of Cuyahoga Falls, 2004-Ohio-1879 (9th Dist.) (limits on vacating arbitration; review for fraud/misconduct)