Griggsville-Perry Community Unit School District No. 4 v. Illinois Educational Labor Relations Board

Angie Hires worked for the Griggsville-Perry Community Unit School District (the district) (defendant). Personal problems began to affect her work performance. The school’s principal, Andrea Allen, encouraged Hires to be more positive and improve her demeanor. At a regularly scheduled school board meeting, Allen recommended that Hires be discharged. Hires was unaware that her performance would be discussed at the meeting or that she would be recommended for discharge. The superintendent wrote Hires a letter notifying her that she was being discharged because she did not relate well to students and was not always pleasant, and that she could respond to these deficiencies at the next school board meeting. Hires’s union, the Griggsville-Perry Federation of Support Personnel IFT-AFT, Local #4141 (the union) (plaintiff), filed a grievance with the district, citing the lack of specificity in the district’s allegations, the lack of notice, and the lack of opportunity for Hires to respond to the deficiencies. The district denied the grievance and terminated Hires after the meeting. An arbitrator determined that the district violated the collective-bargaining agreement (CBA) in place by failing to hold a hearing before discharging Hires. The arbitrator rejected the district’s argument that Hires’s status as an at-will employee was evident from the lack of a just-cause provision in the CBA, which the parties discussed during bargaining but opted not to include in the CBA. However, based on the totality of the language and the parties’ conduct, the arbitrator interpreted the CBA as imposing a standard of arbitrariness for employee dismissals. According to the arbitrator, the district’s decision violated this standard because the allegations against Hires were vague, unsubstantiated assertions, and she was not given a hearing until after the board decided to dismiss her. The arbitrator ordered the district to reinstate Hires. The district refused, arguing that the arbitrator’s decision was not based on an interpretation of the CBA. The union filed an unfair-labor-practice charge with the Illinois Educational Labor Relations Board (the board), which confirmed the amended award. An appellate court held that the arbitrator’s reading of the CBA was clearly erroneous. Both parties appealed.