Fairland Assn. of Classroom Teachers v. Fairland Local Bd. of Edn.

Citation: 2017 Ohio 1098Docket: 15CA23

Court: Ohio Court of Appeals; May 1, 2017; Ohio; State Appellate Court

Original Court Document: View Document

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The Fairland Association of Classroom Teachers, OEA/NEA, and John McClung (Appellants) appeal a judgment from the Lawrence County Court of Common Pleas dated November 9, 2015. Appellants argue the trial court incorrectly upheld a magistrate's decision to grant the Fairland Local School District Board of Education's (Appellee) motion to dismiss their complaint regarding breach of contract and declaratory judgment, claiming the trial court lacked subject-matter jurisdiction. In addition, they assert that the trial court failed to consider their objections to the magistrate’s decision, which they allege did not comply with Civil Rule 53.

The Appellants initiated the lawsuit on March 9, 2015, alleging that the Board breached its Master Agreement with McClung, a teacher and athletic director at Fairland High School during the 2013-2014 school year. They claimed McClung was not timely notified of the non-renewal of his supplemental contract, which was required by Article 32, Section 32.1 of the agreement to be communicated by April 30, 2014. McClung received notice on May 5, 2014. The Appellants also contended that the Board failed to comply with Article 4, Section 4.05(3)(d) regarding the timely provision of a written response to McClung's grievance.

The Appellee moved to dismiss the complaint for lack of subject-matter jurisdiction, which the magistrate granted on June 14, 2015. After Appellants filed objections to the magistrate's decision, the trial court found those objections untimely and noted that Appellants did not request findings of fact and conclusions of law. Consequently, the trial court upheld the magistrate's dismissal and ruled in favor of Appellee. The Appellants subsequently appealed this decision. The court ultimately found no merit in the Appellants’ arguments, overruling their assignments of error and affirming the trial court's judgment.

The document presents two assignments of error from the Appellants. First, it argues that the lower court incorrectly concluded it lacked subject-matter jurisdiction over the Appellants’ claims for breach of contract and declaratory judgment. Second, it contends the court erred by not considering the Appellants’ objections to the magistrate's decision, which allegedly did not comply with Ohio Rule of Civil Procedure 53. The Appellants acknowledge they did not timely file objections, but claim the magistrate's failure to inform them of the objection process should not preclude their appeal.

Subject-matter jurisdiction is defined as a court's authority to hear specific cases, and it can be challenged at any time, regardless of waiver. The document cites legal precedent demonstrating that the trial court's ruling on jurisdiction is a legal question subject to de novo review. The Appellants’ complaint, which involves two alleged breaches of a collective bargaining agreement, asserts that such claims can be filed in the court of common pleas, as the agreement does not require binding arbitration. Conversely, the Appellee argues that the claims are dependent on collective bargaining rights, asserting that jurisdiction lies exclusively with the State Employee Relations Board (SERB) under R.C. Chapter 4117. The Appellants' arguments regarding the second assignment of error are deemed moot due to the overarching issue of subject-matter jurisdiction.

SERB, established under R.C. Chapter 4117, functions as a state agency with jurisdiction defined solely by statutory authority. It holds exclusive jurisdiction over matters pertaining to collective bargaining rights under this chapter, including unfair labor practice charges. Specifically, this exclusivity applies when a party files a charge with SERB or when a complaint in common pleas court alleges conduct defined as an unfair labor practice under R.C. 4117.11. In the case of Franklin Cty. Law Enforcement Assn., the Supreme Court of Ohio determined that the plaintiffs' claims, which relied on rights established by R.C. Chapter 4117, fell entirely within the exclusive jurisdiction of SERB, leading to the dismissal of the complaint for lack of jurisdiction. The court noted that while union members may possess common-law rights, the claims were intrinsically linked to R.C. Chapter 4117's provisions. Additionally, in State ex rel. Cleveland v. Sutula, the Supreme Court addressed a union's complaint regarding the city of Cleveland's obligations under a pre-strike settlement, emphasizing that the jurisdictional question hinged on whether the claims stemmed from collective bargaining rights outlined in R.C. Chapter 4117.

The Sutula court ruled that the State Employment Relations Board (SERB) has exclusive jurisdiction over all matters under R.C. Chapter 4117, not just unfair labor practices. The Supreme Court noted the union's common pleas court case involved allegations of unfair labor practices under R.C. 4117.11(A)(1) and (5), specifically that Cleveland allegedly violated a collective-bargaining agreement, thus interfering with employees' statutory collective-bargaining rights. The court emphasized that the union's claims were based on this agreement and the city's noncompliance with R.C. Chapter 4117. The central issue was whether the union's claims were dependent on collective-bargaining rights under R.C. Chapter 4117. The court concluded that the common pleas court did not have jurisdiction over the union's claims related to R.C. Chapter 4117, as SERB's exclusive jurisdiction meant that judicial intervention was not permitted prior to SERB's action.

In a later case, State ex rel. OCSEA, a union representing Ohio public employees sought a declaratory judgment regarding whether employees at a correctional institution qualified as 'public employees' under R.C. 4117.01(C). The state respondents argued that SERB held exclusive jurisdiction over such matters. The court clarified that the Sutula decision did not extend SERB's jurisdiction beyond what R.C. Chapter 4117 confers, but determined that OCSEA's claim concerning public employee status was indeed under SERB's exclusive jurisdiction.

The excerpt also references Carter v. Trotwood–Madison City Bd. of Edn., where retired teachers challenged the denial of retirement incentives based on a collective bargaining agreement. The trial court dismissed their claims due to the determination that R.C. Chapter 4117 preempted the issue, as SERB had exclusive jurisdiction over allegations of unfair labor practices. The court of appeals upheld this conclusion and referenced the Ohio Supreme Court's caution in E. Cleveland v. E. Cleveland Firefighters Local 500 regarding the broad application of 'arguable' unfair labor practices, indicating complexities in SERB's jurisdiction over such grievances.

Carter's reasoning parallels that of the appellate court in Bringheli v. Parma City School Dist. Bd. of Edn, where permanent part-time school bus drivers contested the dismissal of their complaint against the school board. The school board's motion to dismiss was based on claims of lack of subject-matter jurisdiction, failure to state a claim, and governmental immunity, which the trial court upheld, ruling it lacked subject-matter jurisdiction. The critical issue was whether the appellants' claims were tied to collective-bargaining rights under R.C. Chapter 4117. The alleged breaches included the school board’s failure to notify McClung of the non-renewal of his contract by the stipulated deadline and improper notification of grievance outcomes. The agreement's Articles 32 and 4 clearly delineate procedures for contract non-renewal and grievance notifications, respectively. All employment-related matters are subject to collective bargaining, and McClung's engagement with the grievance process indicated his recognition of the agreement's authority. The court concluded that filing a civil complaint did not remove the matter from the agreement's scope, and the allegations against the school board could be viewed as unfair labor practices. Therefore, jurisdiction over the claims was granted exclusively to SERB. The trial court's decision to dismiss for lack of subject-matter jurisdiction was affirmed, with the court allowing the appellee to recover costs. The judgment mandated execution by the Lawrence County Common Pleas Court and terminated any prior stays. Abele, J. concurred, while Hoover, J. dissented. The document serves as a final judgment, initiating the timeline for potential further appeals.