## Facts

- Angie Hires worked for 11 years as a paraprofessional for Griggsville-Perry Community Unit School District No. 4 and was a member of a union-covered bargaining unit.
- The collective-bargaining agreement (CBA) included a discipline clause requiring “reasonable prior written notice of the reasons” for any meeting before the board “concerning any disciplinary matter,” and permitting a personal representative at that meeting.
- The CBA did not contain an express “just cause” discharge standard.
- The principal documented concerns about Hires’ demeanor and workplace interactions, largely in a private notebook, with limited formal communication to Hires as written warnings or discipline.
- In March 2008, the school board discharged Hires after a board meeting at which she spoke, but she did not receive written notice specifying the reasons or charges leading to possible discharge.
- The union pursued arbitration under the CBA; the arbitrator found the discharge process arbitrary and lacking a fair hearing due to inadequate notice and opportunity to respond, and ordered reinstatement.
- The District refused to comply with the award; the union filed an unfair labor practice charge, and the Illinois Educational Labor Relations Board (IELRB) ordered compliance.
- The appellate court set aside the IELRB order, reasoning the arbitrator exceeded authority by adding requirements not expressly stated in the CBA.
- The Illinois Supreme Court reviewed whether the arbitrator exceeded contractual authority and what standard courts should use when reviewing an IELRB decision resting on an arbitration award.

## Issues

1. Whether the arbitrator exceeded authority under the CBA by interpreting the discipline clause to require a nonarbitrary, fair discharge procedure (including adequate notice) despite the absence of an express just-cause term.
2. What standard of judicial review applies to court review of an IELRB decision that enforces an underlying labor-arbitration award.

## Decision

- The Illinois Supreme Court reversed the appellate court and confirmed the IELRB’s order requiring the District to comply with the arbitration award.
- The Court held the arbitrator did not exceed authority because the award drew its essence from the CBA’s discipline language and the parties’ bargaining history.
- The Court rejected the appellate court’s use of a “clearly erroneous” approach to the arbitrator’s contract interpretation, emphasizing that judicial review of labor-arbitration awards is extremely limited.

## Legal Principles

- When parties choose binding labor arbitration, judicial review of the arbitrator’s award is extremely limited.
- An award is upheld if it “draws its essence” from the CBA; it may be set aside only if it lacks any contractual foundation or does not logically flow from the agreement.
- Courts do not reassess the correctness of an arbitrator’s contract interpretation; they examine only whether the arbitrator acted within the authority granted by the CBA.
- A reviewing court should not use “clearly erroneous” review to re-evaluate an arbitrator’s interpretation of a CBA merely because the enforcement action arises through an agency order.

## Conclusion

The court required enforcement of the reinstatement award because the arbitrator’s fairness-based reading of the CBA’s discipline notice provision was grounded in the agreement and bargaining history, and courts must defer to that contractual construction absent a lack of any contractual basis.


Griggsville-Perry Cmty. Unit Sch. Dist. No. 4 v. Ill. Educ. Labor Rels. Bd., 984 N.E.2d 440 (Ill. 2013)