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November 25, 2022

Resolving a challenge to an arbitrator's decision and award

The petitioner [Union] commenced this proceeding pursuant to CPLR Article 75 seeking to vacate a decision by Supreme Court that an arbitration opinion and award holding that the termination of one of its members was in accordance with the parties' collective bargaining agreement [CBA] with the employer [County] and Supreme Court's granting the County's cross-petition seeking to confirm the arbitrator's opinion and award.

Union had appealed Supreme Court's ruling, contending that Supreme Court was incorrect and that the arbitrator's opinion and award were irrational. In addition, Union argued that the arbitrator had exceeded his authority.

Citing Matter of United Fedn. of Teachers, Local 2, AFT, AFL-CIO v Board of Educ. of City School Dist. of City of N.Y., 1 NY3d 72, the Appellate Division sustained Supreme Court's ruling, explaining that:

1. "An arbitration award may be vacated on three narrow grounds: 'it violates a strong public policy, is irrational, or clearly exceeds a specifically enumerated limitation on the arbitrator's power';

2. "An award is irrational if there is no proof whatever to justify the award, noting the decision in Matter of Town of Greece Guardians' Club, Local 1170, Communication Workers of Am. [Town of Greece], 167 AD3d 1452);

3. "... in this instance the arbitrator's award was justified by the language of the CBA, the CBA's reference to the rules for the Classified Civil Service of the [County] and the parties' past practices," in effect rejecting the Union's claim that the opinion and award were irrational; and concluded that

4. "Contrary to [Union's] further contention, the arbitrator did not exceed his authority by effectively rewriting the CBA or ignoring its terms, and instead interpreted the existing terms of the CBA after finding the language of the CBA to be ambiguous."

Click HERE to access the Appellate Division's decision posted on the Internet.

 

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NYPPL Blogger Harvey Randall served as Principal Attorney, New York State Department of Civil Service; Director of Personnel, SUNY Central Administration; Director of Research, Governor’s Office of Employee Relations; and Staff Judge Advocate General, New York Guard. Consistent with the Declaration of Principles jointly adopted by a Committee of the American Bar Association and a Committee of Publishers and Associations, the material posted to this blog is presented with the understanding that neither the publisher nor NYPPL and, or, its staff and contributors are providing legal advice to the reader and in the event legal or other expert assistance is needed, the reader is urged to seek such advice from a knowledgeable professional.
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