Phila. Fed. of Teachers v. SD of Phila.

The issue raised by this appeal centered on whether power was invested in a school reform commission, under a statutory regime designed to facilitate rehabilitation of financially distressed school districts, to unilaterally alter terms and conditions of employment for teachers whose interests were represented by a bargaining unit. In December 2001, the Secretary of Education issued a declaration of financial distress pertaining to the District, and a school reform commission (SRC or “Commission”) was constituted and assumed responsibility for the District’s operations, management, and educational program, per Section 696 of the School Code. Throughout the ensuing years, the SRC and appellee Philadelphia Federation of Teachers, AFT, Local 3, AFL-CIO (the “Union”), negotiated several collective bargaining agreements. The SRC invoked Sections 693(a)(1) of the School Code, as incorporated into Section 696(i), to “make specific limited changes and to implement . . . modified economic terms and conditions for employees in the bargaining units represented by the [Union], consistent with economic terms proposed in negotiations, while maintaining all other existing terms and conditions to the extent required by law[.]” The Commission predicted that the changes would save about $44 million in 2014 through 2015 and $198 million over four years. Ultimately, the resolution purported to cancel the most recent collective bargaining agreement between the District and the Union, to the extent that it continued to govern the parties’ relations. The Commission, the District, and the Department of Education then filed a declaratory judgment action at the Commonwealth Court, asking the Court to uphold the imposition of the new economic terms and conditions as being authorized by applicable law. The Court found that the right of cancellation under Sections 693(a)(1) and 696(i) did not reach such agreements, and that on account of a prescription within Section 693 that “the special board of control shall have power to require the board of directors within sixty (60) days” to implement measures encompassing the cancellation power, the cancellation power could only have been exercised within 60 days after the December 2001 declaration of distress. The Supreme Court reviewed the Commonwealth Court's judgment, and affirmed the outcome, but on differing grounds. The Supreme Court held at least insofar as teachers were concerned, that collective bargaining agreements were “teachers’ contracts” which were excepted from a school reform commission’s cancellation powers. View "Phila. Fed. of Teachers v. SD of Phila." on Justia Law