State ex rel. Ohio Assn. of Pub. School Emps. v. Willoughby-Eastlake City School Dist., 2022 Ohio 4242

Union (OAPSE/AFSCME Locals 159 & 163) represented nonteaching classified employees under CBAs covering Sept. 1, 2019–Aug. 31, 2021; CBAs included RIF, calamity-day, and grievance-to-final-arbitration provisions.
During the 2020–21 school year the District moved to remote instruction for COVID‑19; on Nov. 19, 2020 the Board implemented reductions in force (RIFs) effective Dec. 16, 2020, suspending wages and health benefits.
The Union sued (mandamus and other relief) alleging the Board violated R.C. 3319.081(G) (pay for nonteaching employees when schools are closed due to an epidemic/public calamity) and sought a preliminary injunction ordering continued pay/benefits.
The trial court granted a preliminary injunction, finding COVID‑19 qualified as an epidemic/public calamity, the schools were “closed,” and employees were “employed” under the statute; ordered continuity of pay/benefits.
The Board appealed, arguing the trial court lacked subject-matter jurisdiction because the CBAs’ grievance procedure (final and binding arbitration) was the exclusive remedy under R.C. 4117.10(A).
The court of appeals held the trial court lacked jurisdiction because the CBAs’ calamity/RIF provisions materially mirror R.C. 3319.081(G), so resolution depended on CBA interpretation and was reserved to the arbitration process; it reversed and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the common‑pleas court had subject‑matter jurisdiction despite CBAs providing final and binding arbitration	Statutory right under R.C. 3319.081(G) is independent of the CBAs, so court may hear claim	R.C. 4117.10(A) and the CBAs’ grievance-to-arbitration clause make arbitration the exclusive remedy	Held for Defendant: no jurisdiction; claims depend on CBA interpretation and must proceed through arbitration
Whether R.C. 3319.081(G) applied (schools were “closed,” COVID‑19 is an "epidemic or public calamity," employees were "employed")	Statute protects employees and prohibits RIF pay suspension during an epidemic/public calamity	Board implemented lawful RIF under CBA language and circumstances	Not decided on merits — rendered moot by jurisdictional ruling
Whether the Union showed entitlement to a preliminary injunction on merits and equities	Union showed likelihood of success, irreparable harm, public interest, and preservation of status quo	Board disputed likelihood of success and harm findings	Not reached — moot after reversal
Whether an evidentiary hearing was required before granting the preliminary injunction	An evidentiary hearing was necessary	Trial court properly exercised discretion without one	Not reached — moot after reversal

State ex rel. Ohio Assn. of Pub. School Emp./AFSCME, Local 4 v. Batavia Local School Dist. Bd. of Edn., 89 Ohio St.3d 191, 729 N.E.2d 743 (discusses interaction of CBAs and statutory rights)
Franklin Cty. Law Enforcement Assn. v. Fraternal Order of Police, Capital City Lodge No. 9, 59 Ohio St.3d 167, 572 N.E.2d 87 (collective‑bargaining remedies framework)
State ex rel. Clark v. Greater Cleveland Regional Transit Authority, 48 Ohio St.3d 19, 548 N.E.2d 940 (statute governs when CBA is silent)
State ex rel. Jones v. Suster, 84 Ohio St.3d 70, 701 N.E.2d 1002 (definition of subject‑matter jurisdiction)
Crawford v. Kirtland Local School Dist. Bd. of Edn., 124 N.E.3d 269 (trial court lacks jurisdiction when resolution requires CBA interpretation)
State ex rel. Brannon v. Lakeview School Bd. of Edn., 62 N.E.3d 1003 (R.C. 3319.081 protects non‑teacher employees; CBA interplay)