Appellate Division Upholds PERC's Authority in Security Camera, Teacher Discipline Cases
The three-judge panel in a published decision said PERC has "exclusive jurisdiction to decide complaints arising under the New Jersey Employer-Employee Relations Act."
July 16, 2018 at 04:02 PM
4 minute read
A New Jersey appeals court ruled that the state's Public Employment Relations Commission has near-exclusive jurisdiction over labor disputes between public workers and their employers.
The three-judge panel in a published decision Monday said PERC has “exclusive jurisdiction to decide complaints arising under the New Jersey Employer-Employee Relations Act.”
“We further hold that the Law Division does not have jurisdiction to enforce an order entered by PERC,” said Appellate Division Judge Jose Fuentes for the panel, joined by Judges Ellen Koblitz and Karen Suter.
The court also upheld a teachers' union's right “to engage in good faith negotiations to ascertain the impact the installation of exposed cameras with both audio and video capabilities would have on the terms and conditions of employment for the employees.”
The appeals court ruling resolves two disputes between the Belleville Education Association, which represents the unionized school district employees in the township, and the Belleville Board of Education.
The first dispute involved the board's decision, which dates back to January 2014, to issue radio frequency identification (RFID) cards to every school employee, and to install video cameras, with audio capability, in virtually all areas of the district schools, though no cameras were installed in restrooms, locker rooms or in the nurses' offices. The board said both measures were to improve security.
The BEA complained about the installations of the cameras, saying it would improperly interfere with its members' ability to discuss union matters.
PERC held that the installation of the cameras was a condition that should have been negotiated between the board and the union. The board appealed in 2015, though arguments were not heard by the Appellate Division until September 2017, by which time, the board already had decided to remove all cameras from its schools or at least have them remain inoperative, the decision notes.
Still, the Appellate Division ruled on the issue, and affirmed.
“In our view, PERC's thoughtful decision properly applied the [In re Local 195 IFPTE, 88 N.J. 393 (1982)] test to strike a proper balance between the Board's managerial prerogative and obligation to ensure the safety of students and staff, and the BEA's right to advocate and negotiate for the interests of its members,” Fuentes wrote. “The issues PERC addressed include, but are not limited to, good faith negotiations concerning the designation of zones of privacy where cameras would not be installed.”
In at least one aspect, the appeals court agreed with the board's reasoning.
“The district has a prerogative, and a responsibility, to take the measures it deems appropriate to protect the safety of its students and staff, particularly in light of the numerous instances of public violence in our schools nationwide in recent past,” Fuentes said.
The second issue, according to the court, involved a disciplinary matter against the union's president, Michael Mignone, whom the board suspended for three months without pay after he allegedly allowed a teacher to listen in on a phone conversation with a parent involving a student. PERC took up the matter and reduced the penalty to 30 days.
Mignone sought relief in Essex County Superior Court, but a trial judge dismissed his action, saying PERC had the authority to decide these work-related matters.
The appeals court agreed.
“[PERC] has the exclusive authority to enforce its own orders and decisions,” Feuntes said, adding that the Law Division “does not have jurisdiction to enforce an order entered by PERC under the summary enforcement proceedings available in Rule 4:67-6.”
The union's attorney, Sanford Oxfeld of Oxfeld Cohen in Newark, said he agreed “with 95 percent of the ruling,” but said he believed the appeals court should have upheld Mignone's right to seek relief in the Law Division.
As for the security cameras, Oxfeld said the district had spent $2 million on the camera system, and then realized it couldn't afford to maintain it. “It was a boondoggle,” he said.
The board's attorney, Stephen Edelstein of Whippany's Schwartz Edelstein, did not return calls seeking comment.
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