Northeast Bradford SD v. Northeast Bradford Education Assoc.. PSEA/NEA, Northeast Bradford SD v. Northeast Bradford Education Assoc.. PSEA/NEA

In June 2014 the Northeast Bradford School District notified three full‑time professional employees (a PE teacher, a reading specialist, and an art teacher) they would be reassigned to part‑time positions for "lack of a need for a full time position;" two initially requested Section 1151 hearings but then withdrew those requests.
The school board approved the reassignments on June 16, 2014; the Association filed grievances asserting the demotions violated the parties’ collective bargaining agreement (CBA).
An arbitrator concluded the CBA covered only full‑time professional employees, contained no management‑rights clause, and the parties had bargained to preserve full‑time employment (including a one‑year extension agreement with no furloughs/layoffs in exchange for a wage freeze). The arbitrator sustained the grievances, ordered reinstatement to full‑time status, and awarded back pay and benefits.
The District petitioned to vacate the award arguing (1) election of remedies/Section 1151 limited employees to board hearings and (2) the arbitrator applied contract interpretation rather than the statutory arbitrary/discriminatory standard in Section 1151.
The trial court denied vacatur, applying the two‑prong ‘‘essence’’ test and finding the award rationally derived from the CBA; the District appealed.
The Commonwealth Court affirmed, holding arbitration was not barred by election of remedies and the arbitrator’s award drew its essence from the CBA.

Issue	Plaintiff's Argument (District)	Defendant's Argument (Association)	Held
Whether the doctrine of election of remedies / Section 1151 bars arbitration	Section 1151 provides the exclusive remedy for demotion (board hearing and appeal); employees who sought hearings elected that remedy, so arbitration is barred	Remedies are not inconsistent: Section 1151 tests arbitrariness/motive, while the CBA/arbitration tests contract/just‑cause issues; employees withdrew hearing requests and pursued arbitration	Arbitration not barred; election of remedies inapplicable because the statutory and contractual remedies address different substantive issues and employees withdrew hearing requests
Whether the arbitrator exceeded authority / misapplied law by not applying Section 1151’s arbitrary/discriminatory standard	Arbitrator should have applied the Section 1151 standard; award conflicts with statute and public policy	Arbitrator properly interpreted and enforced the CBA; award must be reviewed under the essence test and is entitled to deference	Award sustained: it draws its essence from the CBA and the arbitrator’s interpretation is rationally derived from the agreement; no vacatur

Hanover School Dist. v. Hanover Educ. Ass’n, 814 A.2d 292 (Pa. Cmwlth. 2003) (arbitrability of disciplinary/contract disputes under implied just‑cause principles)
East Pennsboro Area Sch. Dist. v. Pa. Labor Relations Bd., 467 A.2d 1356 (Pa. Cmwlth. 1983) (parties’ intent to exclude arbitration is shown by express contract language)
West Middlesex Area Sch. Dist. v. Pa. Labor Relations Bd., 423 A.2d 781 (Pa. Cmwlth. 1980) (statutory School Code remedy and contractual arbitration can coexist; election of remedies applies only when remedies are inconsistent)
State Sys. of Higher Educ. (Cheyney Univ.) v. State Coll. & Univ. Prof’l Ass’n, 743 A.2d 405 (Pa. 1999) (two‑prong ‘‘essence’’ test for review of arbitration awards)
Mifflinburg Area Educ. Ass’n v. Mifflinburg Area Sch. Dist., 724 A.2d 339 (Pa. 1999) (parties may not implement CBA terms inconsistent with statute; statutory conflicts can invalidate contractual provisions)