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Central Dauphin School District v. Central Dauphin Education Association

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ARGUED: September 13, 2000

The Central Dauphin School District (District) appeals from an order of the Court of Common Pleas of Dauphin County that confirmed an arbitration award (Award) in favor of the Central Dauphin Education Association (Union) and that denied the District’s petition to modify, correct or vacate the Award. The District contends that the arbitrator exceeded his authority by establishing a new contract term after finding that the District did not violate the April 15, 1996 collective bargaining agreement (Agreement). The District further contends that the Award does not satisfy the “essence” test.

The factual history of this case is set forth in detail in the Court’s prior decision in the matter. Central Dauphin School District v. Central Dauphin Education Association, 739 A.2d 1164 (Pa. Cmwlth. 1999) (Central Dauphin I). The Union represents teachers who work for the District pursuant to the Agreement. During 1996 and 1997, the District required some of the Union’s members to attend several after-school meetings, and the District compensated the teachers pursuant to the District’s “Memo 10″ document, which sets forth a rate schedule unilaterally established by the District. Although the Memo 10 rate schedule is unilaterally set by the District, the document is specifically referenced in Article III(H) of the Agreement.

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