Williston Education Association v. Williston Public School Dist. No. 1, 876 N.W.2d 437

Williston Education Association (WEA) sued Williston Public School District No. 1 on behalf of middle school teachers, claiming the District owed pay for extra classes in 2012–2013 under the 2011–2013 collective bargaining Agreement.
The Agreement provided: “A 7-8 grade teacher who consents to be assigned more than six (6) class periods shall receive 1/7th of his/her schedule salary for the seventh class period,” but did not define “class period,” “prime time,” “prep period,” or “team time.”
In 2011–2012 some teachers gave up their prep period, taught six curriculum-based periods plus prime time, and were paid 1/7th salary; in 2012–2013 the schedule changed (added a class, shortened prime time, discontinued team time) and those teachers were not paid extra.
WEA filed grievances on behalf of teachers; the superintendent and board president declined to consider them (arguing WEA lacked standing and grievances were untimely), after which WEA sued for breach of the Agreement.
The district court granted summary judgment for WEA, concluding “class period” included prime time; the District appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether WEA could use grievance procedure and sue	WEA may file grievance and sue on behalf of teachers when issue affects majority and interprets the Agreement it negotiated	Only individual "teacher(s)" may invoke grievance; WEA lacked standing and failed to exhaust remedies	WEA may utilize grievance procedure and sue after negotiations failed; district court had jurisdiction
Whether grievance was timely	WEA argued its submissions and subsequent suit were permissible after negotiation breakdown	District argued 10‑day limitation in grievance policy barred WEA action	Court held nothing in Agreement precluded suit after grievance denial/failed negotiations; timeliness did not bar jurisdiction
Meaning of "class period"—does it include prime time?	WEA: prime time is a class period; teachers taught more than six periods and are owed extra pay	District: prime time is not a class period; extra pay in 2011–2012 was for losing prep period, not for prime time	The contract was ambiguous; extrinsic evidence created genuine factual disputes, so summary judgment for WEA was improper and case remanded for trial
Whether summary judgment was appropriate	WEA urged interpretation based on past practice and depositions warranted judgment as a matter of law	District argued course of dealings produced competing inferences precluding summary judgment	Court reversed summary judgment, holding reasonable inferences conflict and factual issues must be tried

Mandan Educ. Ass’n v. Mandan Pub. School Dist. No. 1, 610 N.W.2d 64 (N.D. 2000) (teacher contract interpretation follows general contract rules)
Williston Educ. Ass’n v. Williston Pub. School Dist. No. 1, 483 N.W.2d 567 (N.D. 1992) (prior decision on association suits and negotiation process)
National Bank of Harvey v. Int’l Harvester Co., 421 N.W.2d 799 (N.D. 1988) (contract interpretation principles)
Grinnell Mut. Reins. Co. v. Center Mut. Ins. Co., 658 N.W.2d 363 (N.D. 2003) (contract clauses read in light of overall intent)
Hamilton v. Woll, 823 N.W.2d 754 (N.D. 2012) (summary judgment and inferences from undisputed facts)
Wenco v. EOG Res., Inc., 822 N.W.2d 701 (N.D. 2012) (standard of appellate review for summary judgment)