AI Generated Opinion Summaries

Decision Information

Decision Content

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Facts

  • In March 2008, a union petitioned to represent full-time faculty on nine-month contracts at San Juan College. The College sought to include in the bargaining unit all full-time faculty on nine- and ten-month contracts, as well as full-time instructional professionals with varying percentages of instructional duties, arguing that the proposed unit was too narrow. The Board decided that the appropriate bargaining unit would include only full-time faculty on nine- and ten-month contracts and full-time instructional professionals with 100% instructional duties, excluding those with less than 100% instructional duties and others (para 2).

Procedural History

  • State Public Employer Labor Relations Board: Dismissed the union's petition and remanded to the local Board on the College's motion.
  • San Juan College Labor Management Relations Board: Decided the appropriate bargaining unit would include full-time faculty on nine- and ten-month contracts and full-time instructional professionals with 100% instructional duties, excluding others.
  • District Court of San Juan County: Affirmed the Board's decision.

Parties' Submissions

  • Appellant (San Juan College): Argued that the proposed bargaining unit was unduly restricted and should include all full-time faculty on nine- and ten-month contracts, as well as full-time instructional professionals with 100%, 80%, 60%, and 50% instructional duties.
  • Appellee (San Juan College Labor Management Relations Board): Maintained that the appropriate bargaining unit was correctly defined to include only full-time faculty on nine- and ten-month contracts and full-time instructional professionals with 100% instructional duties, excluding those with less than 100% instructional duties and others.

Legal Issues

  • Whether the Board's decision regarding the composition of a faculty member's collective bargaining unit was supported by substantial evidence and in accordance with law (para 3).

Disposition

  • The Court of Appeals affirmed the district court's decision, which had upheld the Board's determination of the appropriate bargaining unit (para 12).

Reasons

  • The Court, per Judge Roderick T. Kennedy, with Judges Michael D. Bustamante and Michael E. Vigil concurring, held that the Board's decision was supported by substantial evidence and was in accordance with law. The Court applied a deferential standard of review, acknowledging the Board's expertise in determining appropriate bargaining units based on a community of interest and occupational group criteria. The Court found that the Board was not required to identify "the most appropriate" bargaining unit but rather an appropriate unit among potentially several. The College's argument that instructional professionals with less than 100% instructional duties shared an overwhelming community of interest with included employees was not persuasive enough to overturn the Board's decision. The Court concluded that the Board's determination of the bargaining unit, which included full-time faculty on nine- and ten-month contracts and full-time instructional professionals with 100% instructional duties, was reasonable and supported by substantial evidence (paras 4-11).
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