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Halley v. BD. OF SCH. TRUSTEES OF BLACKFORD COUNTY SCHOOL CORP.

Citations: 531 N.E.2d 1182; 1988 Ind. App. LEXIS 1036; 1988 WL 136816Docket: 05A04-8710-CV-311

Court: Indiana Court of Appeals; December 19, 1988; Indiana; State Appellate Court

Narrative Opinion Summary

In a class action lawsuit, teachers from the Blackford County School Corporation challenged the Board of School Trustees' requirement to make up school closure days without additional pay. The teachers claimed this violated the School Closing Statute and breached their collective bargaining agreement. The Board had implemented a flexible calendar following prior school closures, which stipulated make-up days without extra pay. The trial court ruled in favor of the Board, leading to an appeal. The court examined the School Closing Statute, determining that prior to its 1987 amendment, it did not mandate additional compensation for rescheduled days. Furthermore, the court found that the Board's actions did not breach the collective bargaining agreement, as the agreement did not specify exact calendar dates. The court concluded that school boards have the authority to manage school calendars and are not required to negotiate these changes with teachers. The ruling was affirmed, upholding the Board's decision not to pay additional compensation for make-up days, aligning with legislative intent and historical practices.

Legal Issues Addressed

Authority of School Boards Over School Calendars

Application: The court affirmed that school boards have the authority to manage school calendars without needing to negotiate changes with teachers, aligning with prior case law.

Reasoning: In the case of Eastbrook Community Schools v. Indiana Education Employment Relations Board, the court ruled that a school board was not obligated to negotiate the school calendar with teachers.

Collective Bargaining Agreements and School Calendars

Application: The court found that the Board did not breach the collective bargaining agreement by requiring teachers to work rescheduled days without additional pay, as the agreement did not specify calendar dates.

Reasoning: The School Board contends that the teachers' contract mandated teaching one hundred eighty days, with allowances for up to five days each semester that did not need to be rescheduled if schools closed.

Interpretation of School Closing Statute

Application: The court determined that the School Closing Statute, prior to its amendment in 1987, did not mandate additional compensation for rescheduled school days.

Reasoning: The court concludes that the enactment of I.C. 20-6.1-5-9 does not mandate additional compensation for rescheduled days, thus the School Board's refusal to pay did not violate the statute.

Legislative Intent and Statutory Amendments

Application: The court interpreted the 1987 amendment to the statute as a clarification rather than a change in law, indicating no prior requirement for additional compensation for rescheduled days.

Reasoning: Teachers contend that the 1987 amendment to I.C. 20-6.1-5-9, which states they are not entitled to additional compensation for rescheduled days, implies that prior to the amendment, compensation was required.