Shamokin Area School District v. American Federation of State, County, & Municipal Employees District Council 86
20 A.3d 579
| Pa. Commw. Ct. | 2011Background
- Weaver, a Shamokin Area School District groundskeeper, was terminated after cursing at a supervisor and making a threat while on school property.
- Weaver's grievance was submitted to arbitration under the collective bargaining agreement; the arbitrator converted the termination to a four-week suspension, ordered anger management, and placed him on one year of probation.
- The District petitioned to vacate the arbitration award; the trial court vacated the award, citing public policy against violence in schools.
- The Union appealed; the Commonwealth Courtreviews whether reinstating Weaver would contravene public policy.
- The court held the arbitrator’s award did not violate public policy and reversed the trial court’s vacatur.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the arbitration award violate public policy? | Union argues the award is within the CBA and does not contravene public policy. | District argues reinstatement undermines the state public policy against violence in schools. | No public-policy violation; award reinstates Weaver. |
| Did the trial court apply an improper narrow public policy exception? | Union contends Westmoreland exception does not control the review of the award. | District argues the exception should block reinstatement due to safety concerns. | Trial court erred; reversal of vacatur affirmed. |
| What standard governs review of arbitration in this context? | Arbitrator’s findings should be respected under the essence test. | Public policy should limit enforcement when necessary to protect students. | Arbitration award upheld under essence test; deference to arbitrator maintained. |
Key Cases Cited
- Beaver County v. Beaver County, 473 Pa. 576 (Pa. 1977) (essence test; arbitrator’s interpretation must rationally derive from CBA)
- City of Easton v. AFSCME, 562 Pa. 438 (Pa. 2000) (core functions exception to essence test)
- Westmoreland II, 977 A.2d 1205 (Pa. Cmwlth. 2009) (public policy considerations in school-employment disputes)
- Westmoreland I, 595 Pa. 648 (Pa. 2007) (public policy exception to enforcement of arbitration awards)
- Beaver County, S. & E. (Beaver County v. S. & E.), 473 Pa. 576, 375 A.2d 1267 (Pa. 1977) (essence test defining arbitrator’s role and deference)
- Fraser, 478 U.S. 675 (U.S. 1986) (public forum and student conduct considerations)
- Slippery Rock Univ. v. Ass’n of Pa. State Coll. & Univ. Faculties, 916 A.2d 736 (Pa.Cmwlth. 2007) (essence test and deference to arbitration)