Portage Cnty. Bd. of Developmental Disabilities v. Portage Cnty. Educators' Ass'n for Developmental Disabilities, 103 N.E.3d 804

Employee Patricia Byttner (Account Clerk I) was asked to substitute as a bus driver/aide; she refused citing knee surgery and that the duty was not in her job description.
The Portage County Board unilaterally amended her job description to require vehicle operator/attendant duties as needed.
The union grieved; an arbitrator found the board violated the collective-bargaining agreement by adding the duty but held Byttner remained bound by her prior voluntary commitment to occasionally substitute unless she presented medical documentation.
The board moved in common pleas court to vacate the arbitration award under R.C. 2711.10(D); the trial court granted the motion, concluding the arbitrator exceeded his authority.
The court of appeals reversed, applying de novo review and reinstating the arbitration award; the district court certified a conflict on the correct standard of appellate review (de novo vs. abuse of discretion).
The Ohio Supreme Court answered the certified question: appellate courts should accept trial-court factual findings unless clearly erroneous but review questions of law de novo when reviewing a trial court’s decision to confirm, modify, vacate, or correct an arbitration award.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper standard of appellate review of a trial court decision confirming, modifying, vacating, or correcting an arbitration award	Association: appellate review should be de novo (accept non‑clearly erroneous facts; legal questions de novo)	Board: initially urged abuse of discretion to promote arbitration finality; later argued factual-issue deference (clearly erroneous)	Court: Apply First Options framework — accept trial-court factual findings unless clearly erroneous; review questions of law de novo
Whether the arbitrator exceeded his authority under R.C. 2711.10(D)	Association: arbitrator acted within the essence of the CBA and set reasonable limits	Board: arbitrator exceeded powers by rewriting job duties	Court of appeals (and affirmed): under de novo review, arbitrator did not exceed authority; arbitration award reinstated

First Options of Chicago, Inc. v. Kaplan, 514 U.S. 938 (establishes appellate review rule: accept factual findings not clearly erroneous; review legal questions de novo)
Cedar Fair, L.P. v. Falfas, 140 Ohio St.3d 447 (Ohio Supreme Court treating R.C. 2711.10 as substantively equivalent to FAA § 10)
Green v. Ameritech Corp., 200 F.3d 967 (6th Cir.) (whether arbitrator exceeded authority is a question of law)
Richey v. Autonation, Inc., 60 Cal.4th 909 (California Supreme Court applying the same mixed standard of review)