School District of Philadelphia v. Commonwealth Association of School Administrators, Teamsters Local 502
2017 Pa. Commw. LEXIS 147
| Pa. Commw. Ct. | 2017Background
- Marla Travis-Curtis, longtime Philadelphia principal, was terminated in 2014 after the District’s investigation found systematic "beneficial erasures" on PSSA tests at Lamberton; District alleged she participated or was negligent in supervision.
- The Association (union) filed a grievance under the 2013 Collective Bargaining Agreement (CBA), and the parties submitted to arbitration on whether Travis-Curtis was terminated for just cause and, if not, the remedy.
- The Arbitrator found systematic cheating occurred but concluded Travis-Curtis had no credible evidence of direct participation; he found she was negligent in supervision, mitigated termination to a 30-day unpaid suspension and demoted her to assistant principal.
- The School District petitioned the trial court to vacate the award, arguing (1) the Arbitrator exceeded CBA authority by substituting a just-cause analysis and modifying discipline, and (2) reinstating an administrator implicated in cheating violated public policy.
- The trial court vacated the award; the Association appealed. The Commonwealth Court reversed, holding the award drew its essence from the CBA and did not violate the narrow public-policy exception.
Issues
| Issue | Association's Argument | District's Argument | Held |
|---|---|---|---|
| Whether the trial court improperly substituted its view for the Arbitrator by rejecting his interpretation of "cause" | Arbitrator may interpret and apply the CBA term "cause" (including "just cause"); courts may not reweigh arbitrator's contract interpretation | CBA uses "cause" and Section 1122 provides statutory "valid causes," so arbitrator erred by applying "just cause" | Court: Trial court erred; arbitrator's contract interpretation is within arbitration province and review is limited to the "essence" test |
| Whether the Arbitrator exceeded authority by reducing termination to suspension/demotion | Arbitrator had authority to decide just cause and modify discipline absent an express CBA reservation to the employer | CBA reserves District’s sole right to hire, discipline, discharge; arbitrator intruded on District discretion | Court: Arbitrator’s modification rationally flows from CBA; no clear, express provision precluding modification, so arbitrator acted within authority |
| Whether the award must be vacated under the public-policy exception because it reinstates an administrator tied to test cheating | Award does not reinstate an active cheater; Arbitrator found negligence only; public-policy exception applies narrowly and only when award undermines a well-defined, dominant policy | Reinstating any administrator implicated in cheating violates public policy protecting PSSA integrity and should be barred | Court: Public-policy exception not met—the Arbitrator found negligence (not active participation); reinstatement for mere negligent supervision does not contravene a well-defined dominant public policy |
Key Cases Cited
- Office of the Attorney General v. Council 13, Am. Fed'n of State, Cnty. and Mun. Emps., AFL-CIO, 844 A.2d 1217 (Pa. 2004) (arbitrator's interpretation of a CBA is entitled to great deference but must draw its essence from the CBA)
- Westmoreland Intermediate Unit #7 v. Westmoreland Intermediate Unit #7 Classroom Assistants Educ. Support Pers. Ass'n, PSEA/NEA, 939 A.2d 855 (Pa. 2007) (reaffirming essence test and limits on court review of arbitration)
- United Steelworkers v. Enterprise Wheel & Car Corp., 363 U.S. 593 (U.S. 1960) (foundational precedent for the essence test—arbitrator confined to interpreting the collective bargaining agreement)
- City of Bradford v. Teamsters Local Union No. 110, 25 A.3d 408 (Pa. Cmwlth. 2011) (three-step public-policy analysis for vacating arbitration awards)
- Rose Tree Media Secretaries & Educ. Support Pers. Ass'n v. Rose Tree Media Sch. Dist., 136 A.3d 1069 (Pa. Cmwlth. 2016) (arbitrator may modify discipline as part of deciding just cause absent clear CBA limitation)