## Facts

- Idaho’s Professional Negotiations Act authorized negotiation agreements between school boards and professional employees and provided mediation and fact-finding procedures, but did not expressly authorize teacher strikes.
- Oneida Education Association (OEA) was the recognized negotiating representative for teachers employed by School District No. 351.
- In February 1975, OEA sought negotiations; the school board declined to negotiate until after the legislative session recessed, and negotiations did not meaningfully proceed afterward.
- In May 1975, OEA served formal notice to begin negotiations for the 1975–76 school year under the Act.
- The parties executed a procedural agreement (October 1, 1975) addressing negotiation procedures, but they failed to agree on substantive terms (wages and working conditions).
- OEA notified the district that teachers would strike and refuse to report to work around October 15, 1975.
- The school district sued, alleging the threatened strike would breach the procedural agreement and individual teacher contracts and cause irreparable harm; it sought to enjoin striking and picketing.
- At the preliminary-injunction hearing (October 24, 1975), the trial court took no testimony and did not permit evidence, ruling as a matter of law that an injunction should issue.
- The trial court entered a preliminary injunction barring striking and picketing, then entered a “permanent” injunction after a second hearing (January 7, 1976) at which it also received no evidence.
- OEA and its president appealed both injunction orders.

## Issues

1. Whether Idaho public school teachers have any legal right to strike against a governmental employer.
2. Whether a teachers’ strike is illegal for any purpose.
3. Whether Idaho statutes limiting injunctions in “labor disputes” bar injunctive relief in a dispute involving public school teachers.
4. Whether the trial court abused its discretion by issuing a preliminary injunction without complying with traditional equitable standards and procedures.
5. Whether the permanent injunction was an abuse of discretion or overly broad.

## Decision

- The Idaho Supreme Court held that Idaho public school teachers have no legal right to strike against their governmental employer and that such strikes are unlawful.
- The court held that state anti-injunction provisions directed at “labor disputes” did not apply to prevent injunctive relief in this public-sector teacher context.
- The court affirmed the availability of injunctive relief against the threatened strike and related picketing, while emphasizing that ordinary equitable standards govern the issuance and scope of injunctions.
- A separate opinion concurred in part and dissented in part on aspects of the analysis and/or scope of injunctive relief.

## Legal Principles

- Public employees in Idaho, including public school teachers, lack a statutory or common-law right to strike against a governmental employer; a teachers’ strike is unlawful.
- Statutory limits on injunctions in “labor disputes” are not construed to bar courts from enjoining unlawful public-sector teacher strikes.
- Even when the underlying conduct is unlawful, injunctions remain subject to traditional equitable requirements (including consideration of irreparable harm, inadequacy of legal remedies, and appropriate tailoring of the remedy).
- Injunctions must be framed with attention to scope; courts should avoid overbroad restraints not justified by the demonstrated harm and applicable standards.

## Conclusion

The Idaho Supreme Court ruled that public school teachers may not lawfully strike and that courts may enjoin such strikes notwithstanding general anti-injunction labor statutes, while reaffirming that injunctive relief must still conform to ordinary equitable standards and be appropriately limited in scope.


Sch. Dist. No. 351 Oneida Cnty. v. Oneida Educ. Ass’n, 567 P.2d 830 (Idaho 1977)