Webster Education Association v. Webster School District # 18-4 and Board of Education

Summary

The Supreme Court of South Dakota held that a school district's reduction-in-force and teacher-recall policy was subject to mandatory negotiation under SDCL 3-18-3. The court distinguished between the district's managerial discretion to decide whether to reduce staff or recall teachers and the negotiable procedures governing how those decisions are implemented. The court affirmed the Department of Labor's decision and the circuit court's judgment.

Holdings

1. The reduction-in-force and recall policy is a mandatory subject of collective bargaining under SDCL 3-18-3 because it intimately and directly affects the work and welfare of public employees, is not preempted by statute or regulation, and does not significantly interfere with the school district's inherent managerial prerogatives.
2. The school district retains exclusive managerial discretion to decide when to implement its reduction-in-force and recall policy, but the procedures specified in that policy are subject to mandatory negotiation.

Questions Presented

1. Whether the reduction-in-force and recall policy is a mandatory subject of negotiation as an 'other condition of employment' under SDCL 3-18-3.
2. Whether SDCL 13-10-11 and SDCL 13-43-6.4 preempt collective bargaining over the reduction-in-force and recall policy.
3. Whether mandatory negotiation over the policy significantly interferes with the school district's inherent managerial prerogatives.

Disposition

affirmed