Part-time Faculty Association v. Columbia College Chicago, No. 17-3492 (7th Cir. 2018)
Annotate this CaseThe National Labor Relations Board (NLRB) ruled that full-time staff members who also teach part-time (50-75 individuals, “FTST”) were included in the Part-Time Faculty Association at Columbia College Chicago (PFAC) bargaining unit for the purposes of their part-time faculty duties. Under the collective bargaining agreement’s recognition clause FTST are part-time faculty members and arguably fall under the scope of the general inclusion but also qualify as full-time staff members, which are expressly excluded from representation. An arbitrator vacated the ruling. The Seventh Circuit upheld the NLRB decision. Given the primacy of the NLRB’s determination, the countervailing arbitration decision cannot stand. The National Labor Relations Act, 29 U.S.C. 159, “confers broad discretion on the Board to determine appropriate bargaining units,” because “the bargaining unit determination is a representational question reserved in the first instance to the Board.”
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