Philadelphia Federation of Teachers, AFT, Local 3 v. School District of Philadelphia
144 A.3d 1281
| Pa. | 2016Background
- In 2001 the Pennsylvania Secretary of Education declared the School District of Philadelphia distressed and a five-member School Reform Commission (SRC) assumed control under 24 P.S. §6-696.
- The SRC attempted in October 2014 (Resolution SRC-1) to cancel or modify economic terms of the collective bargaining agreement (CBA) with the Philadelphia Federation of Teachers to implement cost-saving measures, claiming authority under the Distressed School Law (24 P.S. §6-693), as incorporated by §6-696(i).
- The SRC relied on §6-693(a)(1)’s cancellation power for contracts “other than teachers’ contracts,” arguing that that phrase refers only to individual tenure/employment contracts, not CBAs.
- The Union filed grievance, unfair-labor-practice charge, and an equity complaint seeking injunctive relief to preserve the status quo; the trial court granted a preliminary (later permanent) injunction preventing the SRC’s unilateral changes.
- The Commonwealth Court affirmed, holding that the SRC could not cancel or unilaterally impose new terms on teachers’ collective bargaining agreements; the Supreme Court of Pennsylvania granted review and affirmed the Commonwealth Court (on different grounds), holding that CBAs covering teachers fall within the exception “teachers’ contracts.”
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the SRC may unilaterally cancel or modify teacher CBAs under §6-693(a)(1)/§6-696(i) | Union: "Teachers’ contracts" includes collective bargaining agreements; SRC lacks unilateral cancellation authority over teacher CBAs | SRC: "Teachers’ contracts" is a term of art meaning individual teacher tenure/employment contracts, so CBAs are subject to cancellation; SRC needs power to address fiscal emergency | Held: "Teachers’ contracts" subsumes CBAs for teachers; SRC cannot cancel or unilaterally impose new terms on teacher CBAs under §6-693(a)(1)/§6-696(i) |
| Whether the SRC’s cancellation power was time-limited to 60 days after declaration of distress | Union: cancellation beyond status quo not permitted; SRC acted late | SRC: 60‑day limitation applies to subordinate board’s compliance, not to SRC’s exercise of powers | Held: Commonwealth Court was correct to reject a 60-day bar on SRC exercising cancellation powers, but Supreme Court decision did not rely on a 60-day limitation for its disposition |
| Whether legislative amendments (Act 46/2001/2012) altered scope of SRC power over CBAs | Union: Amendments and §6-696(k) preserve collective bargaining and status quo for CBAs; legislative history shows intent to protect teachers’ agreements | SRC: Subsequent amendments, repeals, and exemptions confirm SRC’s broad remedial cancellation authority, including over CBAs | Held: Statutory text, ordinary meaning, precedent, and policy support that protections for "teachers’ contracts" include CBAs covering teachers; amendments do not show intent to permit SRC to cancel teacher CBAs |
| Whether judicial/legislative history and common usage support SRC’s narrow reading of "teachers’ contracts" | Union: Common parlance and multiple judicial uses treat CBAs as teachers’ contracts; PERA and bargaining regime weigh against unilateral cancellation | SRC: Historical context (pre-PERA) and earlier case language show "teachers’ contract" referred to individual contracts | Held: Court adopts ordinary/common usage that "teachers’ contracts" encompasses teachers’ CBAs; historical pre-PERA usage does not control modern meaning |
Key Cases Cited
- Oliver v. City of Pittsburgh, 11 A.3d 960 (Pa. 2011) (plenary review of statutory construction)
- PLRB v. State College Area Sch. Dist., 337 A.2d 262 (Pa. 1975) (purpose of PERA to restore labor stability in public sector)
- Smith v. School District of Township of Darby, 130 A.2d 661 (Pa. 1957) (broad reading of school authorities’ powers; rules on construing restrictions narrowly when public interest predominates)
- Leechburg Area School District v. Leechburg Education Ass’n, 380 A.2d 1203 (Pa. 1977) (discusses relationship between individual contracts and collective bargaining)
- Skeim v. Indep. Sch. Dist. No. 115, 234 N.W.2d 806 (Minn. 1975) (describes collective bargaining agreement as a "master teachers’ contract")