Patrolmen's Benevolent Assn. v. City of Munroe Falls

Summary

The Ohio Court of Appeals reversed summary judgment for the Ohio Patrolmen's Benevolent Association in an action seeking to compel arbitration of grievances concerning scheduling part-time police officers. The court held that the second grievance was barred by res judicata because the same issue had been resolved through the collective bargaining agreement's Step 2 grievance process, which made the decision final when arbitration was not timely requested. The court entered summary judgment in favor of the City of Munroe Falls.

Holdings

1. Whether a controversy is arbitrable under an arbitration provision is a question of law for the court, not the arbitrator, to decide.
2. The later grievances were barred by res judicata because the earlier grievance involved the same matter, the individual officers were in privity with the OPBA's represented bargaining-unit members, and the earlier grievance became a final adjudication when the union failed to demand arbitration within the CBA's ten-day deadline.
3. Summary judgment was appropriate for Munroe Falls because the material facts were undisputed and the City's res judicata defense entitled it to judgment as a matter of law.

Questions Presented

1. Whether the trial court properly granted summary judgment to the OPBA and denied summary judgment to Munroe Falls.
2. Whether the court or an arbitrator should decide the City's defense that the later grievances were barred by res judicata.
3. Whether the later grievances were barred by res judicata because the same issue had previously been resolved through the CBA's Step 2 grievance process.

Disposition

reversed