## Facts

- Teamsters Locals 639 and 730 were the certified exclusive bargaining representatives for certain District of Columbia Public Schools (DCPS) employees, including food service workers, bus drivers and attendants, custodians, and engineers serving roughly 70,000 students.
- DCPS and the Teamsters negotiated intermittently over a collective bargaining agreement beginning in 1996, with negotiations resuming in late 1999 after a hiatus.
- The Teamsters sought bonuses and pay raises comparable to those obtained by other bargaining units and warned DCPS officials of a “serious disruption” if demands were not met.
- In mid-January 2000, union leadership communicated that a work stoppage was likely; union members then voted overwhelmingly to strike.
- DCPS stated it was making progress on bonuses but lacked funds for raises; the union deferred action briefly but threatened a work stoppage if no agreement was reached by a set date.
- The Superintendent of Schools and the District sued in D.C. Superior Court to enjoin the threatened strike; the court issued a temporary restraining order and later, after an evidentiary hearing, entered a preliminary injunction.
- The trial court found the threatened strike unlawful, found irreparable injury from disruption of essential school operations, and concluded the balance of harms and public interest favored an injunction.
- The union and its president appealed, challenging the Superior Court’s jurisdiction and the propriety of preliminary injunctive relief.

## Issues

1. Whether the Comprehensive Merit Personnel Act (CMPA) vested exclusive jurisdiction in the Public Employee Relations Board (PERB) such that the Superior Court lacked authority to enjoin the threatened strike.
2. Whether the federal Norris-LaGuardia Act barred the Superior Court from issuing an injunction in a labor dispute involving public-sector employees and a District agency.
3. Whether a strike by DCPS employees constitutes an unlawful strike “against the District” under District of Columbia law.
4. Whether the trial court abused its discretion in granting a preliminary injunction, including whether irreparable harm, balance of equities, and “unclean hands” were properly assessed.

## Decision

- The District of Columbia Court of Appeals affirmed the preliminary injunction.
- The Superior Court had jurisdiction to enjoin an illegal public-employee strike sought to be prevented by the Superintendent and the District; PERB’s authority under the CMPA did not displace that equitable power.
- The Norris-LaGuardia Act did not bar the injunction because it addresses federal-court injunctions and is aimed at private-sector labor disputes, not a dispute between the District and its employees.
- The threatened work stoppage by DCPS employees was prohibited by District law as a strike against the District.
- The trial court did not abuse its discretion in finding irreparable harm and that the public interest and balance of hardships favored preventing the unlawful strike; alleged bargaining deficiencies did not bar relief under an “unclean hands” theory.

## Legal Principles

- D.C. Superior Court retains equitable authority to enjoin an illegal public-employee strike, even where PERB has statutory responsibility for unfair labor practice matters under the CMPA.
- The Norris-LaGuardia Act does not restrict D.C. local courts from enjoining public-sector strikes involving a District agency and public employees.
- A threatened strike by DCPS employees is treated as a strike against the District and may be enjoined when prohibited by District law.
- In assessing preliminary injunctive relief against a threatened unlawful strike, courts may consider irreparable disruption to essential public services, the balance of hardships, and the public interest; alleged bad-faith bargaining does not legalize an illegal strike and does not necessarily bar injunctive relief.

## Conclusion

The court upheld a preliminary injunction preventing a threatened strike by DCPS employees, holding that the Superior Court had jurisdiction notwithstanding PERB’s role under the CMPA, the Norris-LaGuardia Act did not apply, the strike would be unlawful under District law, and the trial court properly found irreparable harm and strong public-interest grounds for injunctive relief.


Feaster v. Vance, 832 A.2d 1277 (D.C. 2003)