American Federation of Teachers v. Ledbetter

387 S.W.3d 360 (2012)

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American Federation of Teachers v. Ledbetter

Missouri Supreme Court
387 S.W.3d 360 (2012)

Facts

The St. Louis local affiliate of the American Federation of Teachers (union) (plaintiff) appointed representatives to act on its behalf to reach a collective-bargaining agreement with the board of the Construction Career Center Charter School (board) (defendant). The negotiators for the union and the board reached a tentative collective-bargaining agreement, but the board voted unanimously to reject it. At a closed meeting, the board then unilaterally enacted a teacher salary scale for the upcoming school year. The board informed the union of the salary scale and presented the union with the board’s preferred contract. The union offered a counterproposal, which the board rejected. The union filed an action in state court claiming that the board had violated its duty to bargain in good faith with the union’s representatives. The trial court granted summary judgment in favor of the board, holding that the board did not have a duty to bargain in good faith. The union appealed.

Rule of Law

Issue

Holding and Reasoning (Breckenridge, J.)

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