BREVARD FEDERATION OF TEACHERS, LOCAL 2098, FEA/UNITED, AFL-CIO, APPELLANTS,
v.
THE SCHOOL BOARD OF BREVARD COUNTY, APPELLEE
AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.
The Brevard Federation of Teachers appealed the trial court's decision to set aside an arbitrator's order interpreting a collective bargaining agreement provision on extra teacher compensation. The court reversed, holding that the arbitrator's interpretation of the contract was binding and not an improper alteration of the agreement's terms.
The arbitrator did not exceed his authority or alter the agreement's terms. When an arbitrator's interpretation of a contract differs from what a party would prefer, this does not render the interpretation an alteration or indicate the arbitrator exceeded his scope. The arbitrator's decision is binding when the issue being arbitrated is within the scope of the parties' agreement and the arbitrator's authority.
[1] An arbitrator's award entered pursuant to Section 447.401, Florida Statutes (1977), may be set aside if the arbitrator exceeds his authority or acts beyond the provisions…
[2] An arbitrator's interpretation of a contract provision, even if not the interpretation favored by a party or the court, does not constitute an alteration of the contract…
Previewing 2 of 4 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“We find no evidence that the issue being arbitrated was beyond the scope of the parties' agreement and the arbitrator's authority. That being so, his decision is binding.”
Establishes that when an arbitrator acts within his authority and the dispute falls within the agreement's scope, the arbitration decision is binding and cannot be overturned by a court.
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceThe Brevard School Board and teachers' union submitted to binding arbitration under Florida Statutes Section 447.401 regarding the interpretation of t…
The full statement of facts, procedural history, and disposition for this case are member content.
Join FLexlaw to unlock all legal intelligence© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.
Explore caselaw by topic → Browse Action To Set Aside Arbitration Award cases and more on FLexlaw
ANSTEAD, Judge.
This appeal is from a final judgment setting aside an arbitrator’s order entered pursuant to the provisions of Section 447.401, Florida Statutes (1977). The parties resorted to binding arbitration under that section following their failure to agree on the interpretation to be given a provision of their collective bargaining agreement relating to extra compensation for teachers required to work beyond the normal workday. The arbitrator conducted a hearing and issued a well reasoned order finding in favor of the appellants. The appellee then filed an action in circuit court claiming that the arbitrator exceeded his authority and acted beyond the provisions of the parties’ agreement. After hearing, the trial court ruled that the arbitrator had altered the terms of the parties’ agreement and the arbitration order was set aside. We reverse.
The issue before the arbitrator involved construction of a provision of the parties’ agreement defining a teacher’s normal workday. Both parties submitted evidence and contended for different constructions. The arbitrator found for the teachers, and there is abundant evidence to support his conclusion. We find no evidence that the issue being arbitrated was beyond the scope of the parties’ agreement and the arbitrator’s authority. That being so, his decision is binding. Lake County Education Association v. School Board of Lake County, 360 So. 2d 1280 (Fla.2d DCA 1978). In West Des Moines Community School District v. West Des Moines Educational Support Personnel, 265 N.W. 2d 625 (Iowa 1978), the Iowa Supreme Court commented in a similar case:
As is typical in an action arising from an arbitration decision, the complaining party urges the arbitrator exceeded his authority and altered terms of the employment contract. However we believe it is clear the arbitrator merely interpreted the contract in a way the school district would not and in a manner we might not. But this does not render the arbitrator’s interpretation an alteration. (Id. at 626)
In addition, the appellee, while making no direct claim that Section 447.401 is unconstitutional, contends that it cannot be held responsible for compensation to teachers for which it made no specific provision in its budget. While sympathizing with its planning and budgetary problems, it is our conclusion that the answers to such problems rest within the authority of the legislature rather than with the courts.
Accordingly, the judgment of the trial court is reversed with directions that judgment be entered in accordance with the terms of this opinion.
DAUKSCH, J., concurs.
CROSS, J., dissents without opinion.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- The Lake Cnty. Educ. Ass'n v. The Sch. Bd. OF Lake Cnty., 360 So. 2d 1280 (Fla. 2d DCA 1978)