Providence School Board v. Providence Teachers Union, Local 958, AFT, AFL-CIO

Summary

The Rhode Island Supreme Court affirmed an order vacating an arbitration award concerning the calculation of health-insurance premium rates for retired Providence teachers. The Court held that the teachers’ union lacked authority under the collective-bargaining agreement to pursue the grievance on behalf of retirees, making the dispute non-arbitrable. Because the arbitrator exceeded his powers, the arbitration award was properly vacated.

Holdings

1. The union lacked standing to pursue this grievance because retirees were excluded from the collective-bargaining unit, the union's contractual jurisdiction, and the definition of teacher, and the collective-bargaining agreement did not authorize the union to grieve on behalf of retirees.
2. Because the union lacked authority to pursue the retiree grievance, the dispute was not arbitrable and the arbitrator exceeded his powers; the Superior Court was therefore required to vacate the arbitration award.

Questions Presented

1. Whether the union had standing under the collective-bargaining agreement to pursue a grievance concerning health-insurance premiums charged to retirees.
2. Whether the arbitration award was properly vacated because the union's grievance on behalf of retirees was not arbitrable.

Disposition

affirmed