Montgomery County Education Association, Inc. v. Board of Education of Montgomery County

Maryland state law empowered public school employers and representatives of employees to negotiate a collective-bargaining agreement covering salaries, hours, and other working conditions. In 1970 the Board of Education of Montgomery County (the county) (defendant) unilaterally adopted a school calendar and reclassified certain positions. The Montgomery County Education Association (the union) (plaintiff), representing teachers in the county, claimed that this violated the collective-bargaining agreement (CBA) in place at the time. The Maryland State Board of Education (the board) ruled that the county was not required to negotiate either of the issues. In 1983, during negotiations for a new CBA, the union submitted a proposal that covered the two subjects. The county declined to negotiate, relying on the board’s previous ruling. The union subsequently asked the board to overrule its previous decision, which it declined to do, concluding that the subjects were not mandatory subjects of bargaining and that allowing bargaining would lead to practical difficulties for the county. A circuit court agreed with most of the board’s conclusions but held that the salary impact of reclassification decisions was a mandatory subject of collective bargaining and reversed that part of the board’s ruling. The intermediate appellate court reversed in part on the ground that the board’s decision should have been regarded as final. The union appealed.