Education Minnesota-Chisholm v. Independent School District No. 695

Summary

The Minnesota Supreme Court affirmed the exclusion of six Early Childhood Family Education instructors from a teachers' bargaining unit. The court held that the instructors provided community education instruction offered on a noncredit basis under the Public Employment Labor Relations Act and therefore were not public employees under the applicable statutory exclusion. The court concluded that the statutory language was clear and unambiguous.

Holdings

1. The phrase is clear and unambiguous as applied to the ECFE program. Instruction is offered on a noncredit basis when it does not result in academic advancement, certification, graduation, or a similar outcome.
2. The six part-time ECFE instructors were properly excluded from the teachers' bargaining unit because their instruction was community education offered on a noncredit basis, and they therefore did not qualify for the statutory exemption from the part-time-employee exclusion.
3. Because the statutory language is clear and unambiguous, the court did not need to examine legislative history.

Questions Presented

1. Whether Early Childhood Family Education instruction is community education instruction offered on a noncredit basis under Minn. Stat. § 179A.03, subd. 14(i).
2. Whether the ECFE instructors therefore qualify as public employees and teachers who must be included in the union's bargaining unit under the Public Employment Labor Relations Act.
3. Whether the statutory phrase "offered on a noncredit basis" is ambiguous as applied to ECFE instruction.

Disposition

affirmed