State Employment Relations Board v. Adena Local School District Board of Education

613 N.E.2d 605 (1993)

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State Employment Relations Board v. Adena Local School District Board of Education

Ohio Supreme Court
613 N.E.2d 605 (1993)

  • Written by Rose VanHofwegen, JD

Facts

A teachers’ union filed charges for teacher Daniel Kelley with the Ohio State Employment Relations Board (SERB) (plaintiffs) alleging the Adena Local School District Board of Education (the school board) (defendant) discontinued Kelley’s teaching contract because of his union involvement. Kelley began working at Adena High School in 1976 under a series of contracts. Despite eligibility for a continuing contract, in 1984 the school board gave Kelley a two-year probationary contract, ending his employment in 1986. SERB found the school board committed an unfair labor practice (ULP) that violated Ohio labor laws. The school board petitioned challenging that decision. The trial court used an “in-part” test for causation that SERB used in mixed-motive cases, found retaliating against Kelley for participating in protected union activities motivated the school board at least in part, and affirmed the school board had committed a ULP. The appellate court found the trial court used the wrong test and ordered the case remanded with directions to apply a but-for causation test instead. Kelley appealed to the Ohio Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Resnick, J.)

Concurrence (Wright, J.)

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