Pennsylvania Labor Relations Board v. Bald Eagle Area School District
Supreme Court of Pennsylvania · 1982-10-26 · cited 51×
The case concerned whether a grievance by a teachers' union over entitlement to one day's pay under a collective bargaining agreement (for a 183-day school year) was subject to compulsory arbitration, even though a state law under the Public Employee Relations Act (PERA) prohibits paying public employees for time spent on strike. The Pennsylvania Labor Relations Board (PLRB) ruled the dispute arbitrable and ordered the school district to proceed, but lower courts reversed, holding it non-arbitrable because a favorable award would violate the no-strike-pay policy. The Supreme Court reversed the Commonwealth Court, reinstating the PLRB order without reaching the merits of the pay dispute. It reasoned that PERA Section 903 mandates arbitration of grievances arising from collective bargaining agreements in the first instance, that arbitrators are bound by statutes like PERA Sections 703 and 1006, and that any conflict with public policy can be addressed through post-award judicial review rather than preliminary court litigation over arbitrability.