Mountain Valley Education Association v. Maine School Administrative District No. 43

Maine state law established a procedure for public-sector collective bargaining. The Maine Labor Relations Board (the board), in its capacity to implement and enforce public labor law, adopted a rule whereby an employer could not unilaterally increase or decrease wages during bargaining and before an impasse. Under the rule, both parties were required to maintain the status quo during bargaining. In 1978 the board implemented an impasse exception to the rule, which allowed a party to unilaterally implement its last best offer if negotiations came to a bona fide impasse. This exception provided that if the parties exhausted the prospects of forming an agreement, unilateral change consistent with the pre-impasse proposals was permissible under state law. The duty to bargain in good faith still applied. State law dictated that an impasse was not officially reached until specified forms of intervention—mediation and arbitration—were exhausted. Under state law, arbitration was binding on all subjects except for wages, salary, and insurance. The Mountain Valley Education Association (plaintiff) (the union) entered into negotiations with Maine School Administrative District No. 43 (the district) (defendant) to form an employment contract for teacher aides and assistants. During mediation, both parties submitted proposals on several issues, including wages, health insurance, and duration of the contract. An arbitration panel issued nonbinding recommendations on wages, retirement, and insurance, but imposed a two-year duration of contract for the upcoming school years. Thereafter, the district sent a new proposal to the union, which was an improvement over its previous proposals, but fell short of the arbitrator’s recommendations. The proposal was rejected, and a counterproposal was made. The district then notified the union it was submitting its last best offer on wages and insurance. The union immediately filed for further mediation. The district unilaterally implemented its wage and insurance proposals. The union filed a complaint with the board, alleging that the district violated state law by unilaterally implementing its proposal and failing to adhere to the arbitrator’s recommendations for a two-year duration of the contract. The board found that the district did not violate state law by unilaterally implementing its wage and hour proposals. On appeal, the superior court affirmed the board’s order. The union appealed the ruling.