314 P.3d 647
Mont.2013Background
- Roberts was a vocational agriculture instructor and FFA adviser at Lame Deer High School; she was suspended with pay August 12, 2009, and terminated November 16, 2009.
- Her termination was appealed to binding arbitration under the collective bargaining agreement; Arbitrator Michael D. McDowell held hearings in August 2010 and denied Roberts’ grievance on November 13, 2010.
- The Arbitrator found the School District afforded due process, had good cause for discipline, and should not reduce the discharge.
- Roberts petitioned the Sixteenth Judicial District Court to vacate, modify, or correct the arbitration award; the District Court denied relief on April 1, 2013, finding she failed to prove any statutory grounds for vacatur/modification.
- On appeal to the Montana Supreme Court, Roberts argued the arbitrator exceeded his powers, the suspension lacked required notice/hearing, the School District acted with improper motive, and various factual errors warranted vacatur or modification.
- The Supreme Court reviewed only whether the District Court abused its discretion in refusing to vacate/modify; it affirmed, holding Roberts did not meet the narrow statutory or "manifest disregard" standards and that the arbitrator stayed within the submitted issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether arbitrator exceeded power by not requiring "good cause" before suspension | Roberts: suspension required prior notice/hearing; arbitrator ignored contract protections | School District: arbitrator resolved the submitted good-cause issue; no statutory or legal violation shown | Court: No abuse of discretion; Roberts failed to show a clearly governing Montana law the arbitrator blatantly disregarded |
| Whether arbitrator improperly considered insubordination before/after termination | Roberts: arbitrator relied on incidents outside the scope/timing of the contract issues | School District: matters were within the scope of the grievance (whether dismissal was for good cause) | Court: Arbitrator decided only the submitted issue (good cause); not an excess of power |
| Whether arbitrator erred by conflating teaching contract with FFA adviser role | Roberts: arbitrator failed to distinguish contractual roles and obligations | School District: arbitrator addressed relevant conduct affecting employment and remedy | Court: Court will not reweigh merits; modification/correction inappropriate; no statutory ground shown |
| Whether arbitrator wrongly held Roberts controlled FFA funds | Roberts: she was only an adviser and did not control FFA funds | School District: arbitrator considered evidence on fund control as relevant to conduct | Court: Factual disputes were for arbitrator; courts may not revisit merits or reweigh evidence |
Key Cases Cited
- Colstrip Energy L.P. v. N.W. Corp., 360 Mont. 298, 253 P.3d 870 (2011) (judicial review of arbitration awards is strictly limited; courts may only act under specified statutory grounds)
- Geissler v. Sanem, 285 Mont. 411, 949 P.2d 234 (1997) (adopted "manifest disregard of the law" standard for vacating arbitration decisions)
- Paulson v. Flathead Conserv. Dist., 321 Mont. 364, 91 P.3d 569 (2004) (clarifies requirements for manifest-disregard review)
- Terra W. Townhomes, L.L.C. v. Stu Henkel Realty, 298 Mont. 344, 996 P.2d 866 (2000) (arbitrator exceeds powers when deciding matters not submitted to him)
- Dick Anderson Constr., Inc. v. Monroe Constr. Co., LLC, 353 Mont. 534, 221 P.3d 675 (2009) (courts should not conduct new evidentiary hearings on matters previously submitted to binding arbitration)