Belanger v. Matteson
Rhode Island Supreme Court
346 A. 2d 124, 115 R.I. 332 (1975)
- Written by Mike Begovic, JD
Facts
The Warwick School Committee (defendant) had a collective-bargaining agreement with the Warwick Teachers Union (the union) (defendant), which provided that promotions be carried out on the basis of qualifications, and that if qualifications were equal, seniority would prevail. In 1972 a teacher in the district, Richard Belanger (plaintiff), was promoted to a position as business-department head of a high school. Belanger’s promotion came at the expense of another teacher, Arthur Matteson (defendant), who had greater seniority. Matteson asked the union to file a grievance on his behalf. The union obliged, and the case proceeded to arbitration. The union did not contact Belanger to ascertain his qualifications or give him a chance to submit information. After a hearing, the arbitrator ruled that Matteson, not Belanger, should have received the promotion. Belanger filed suit against the district, the union, the arbitrator, and Matteson to set aside the award, contending that the union breached its duty of fair representation toward him by pursuing Matteson’s grievance. The superior court vacated the award. Matteson and the union appealed.
Rule of Law
Issue
Holding and Reasoning (Kelleher, J.)
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