## Facts

- Montgomery County Education Association, Inc. (MCEA) served as the designated representative for certain professional public school employees in Montgomery County.
- In 1970, the local board adopted a school calendar and reclassified staff positions without bargaining; the State Board of Education ruled in an administrative decision that the board was not required to negotiate either subject.
- From 1970 to 1983, the parties entered successive collective bargaining agreements without a successful challenge to the earlier administrative ruling.
- During 1983 bargaining, MCEA proposed terms addressing the school calendar and job reclassification; the board refused to negotiate those subjects based on the prior administrative ruling.
- MCEA petitioned the State Board to require bargaining over the calendar and reclassification; a hearing examiner recommended reaffirming nonnegotiability and suggested, as to reclassification, a limited “across-the-board” salary-protection concept for employees whose pay would be reduced.
- The State Board rejected mandatory bargaining over the calendar and reclassification and declined to impose the proposed salary-protection requirement.
- On judicial review, the circuit court agreed most issues were nonnegotiable but held the salary impact of reclassification was a mandatory bargaining subject; the intermediate appellate court reinstated the State Board’s position.
- The Court of Appeals of Maryland granted review to determine the scope of mandatory bargaining under Maryland Code, Education Article § 6-408.

## Issues

1. Whether, under Md. Code, Educ. § 6-408(b)(1), a teachers’ exclusive representative may compel a local board of education to negotiate over the school calendar.
2. Whether job reclassification decisions, including their salary consequences and proposed salary-protection provisions, are mandatory subjects of bargaining under § 6-408.
3. What level of deference courts should give the State Board of Education’s interpretation of the Education Article when determining negotiability boundaries.

## Decision

- The Court of Appeals held that neither the school calendar nor job reclassification is a mandatory subject of bargaining under § 6-408.
- The Court also held that the salary consequences of reclassification, including an “across-the-board” salary-protection proposal tied to reclassification, are not mandatory bargaining subjects.
- The Court deferred to the State Board’s construction of the Education Article and its determination that these matters fall within local board managerial and educational-policy authority.
- The Court affirmed the outcome upholding the board’s refusal to negotiate the disputed topics.

## Legal Principles

- Mandatory bargaining under Educ. § 6-408(b)(1) (“salaries, wages, hours, and other working conditions”) must be read in harmony with statutes assigning local boards responsibility for educational policy and system management.
- Not every decision that affects employees’ work life is a mandatory bargaining subject; matters closely tied to educational policy or managerial prerogatives may be excluded from compulsory negotiation.
- Establishing a school calendar is treated as an educational-policy and management function reserved to the local board rather than a mandatory “hours/working conditions” bargaining topic.
- Job reclassification decisions are managerial determinations reserved to the local board; proposals that would constrain reclassification outcomes, including salary-protection rules triggered by reclassification, are not mandatory bargaining subjects.
- Courts give substantial weight to the State Board of Education’s interpretation of education statutes and its policy judgments allocating authority between employee representatives and school boards.

## Conclusion

The Court of Appeals of Maryland upheld the State Board’s determination that a local board cannot be compelled to bargain over the school calendar or job reclassification, including the salary effects of reclassification, because these subjects fall within the board’s reserved educational-policy and management authority rather than § 6-408’s mandatory bargaining sphere.


Montgomery Cnty. Educ. Ass'n, Inc. v. Bd. of Educ. of Montgomery Cnty., 311 Md. 303, 534 A.2d 980 (Md. 1987)