New Jersey Supreme Court Decision: Overview

On February 12, 2024, the New Jersey Supreme Court decided Amada Sanjuan v. School District of West New York, which addressed the scope of an arbitrator’s discretion under the Tenure Employees Hearing Law (TEHL) regarding penalties for conduct unbecoming by a tenured employee. The case stemmed from the Board of Education of West New York’s certification of tenure charges against Amada Sanjuan for alleged conduct unbecoming following an incident where security footage contradicted her report of an accident at school. The arbitrator, assessing the incident and Sanjuan’s long service, opted for demotion instead of termination without back pay.

Read the entire published decision here on NJCourts.gov

Facts and Procedural History

The legal issue centered on whether N.J.S.A. 18A:6-16 limits an arbitrator to imposing only dismissal or reduction in salary as penalties under the TEHL. The trial court supported the arbitrator’s decision, but the Appellate Division vacated this, interpreting the statute as allowing only termination or salary reduction. The Supreme Court reversed the Appellate Division’s decision, holding that N.J.S.A. 18A:6-16 does not restrict the penalties an arbitrator may impose, thus reinstating the arbitrator’s award.

Legal Issue and Supreme Court’s Rationale

The Court’s rationale emphasized the broad discretion historically granted to arbitrators in imposing penalties under the TEHL, unaffected by the procedural changes introduced by the TEACHNJ Act. This decision underscores the Court’s deference to the arbitrator’s judgment and the flexibility in addressing tenure charges, reaffirming that the law does not limit the imposition of penalties to dismissal or salary reduction alone.

Key Takeaways from the NJ Supreme Court Decision

In conclusion, the New Jersey Supreme Court’s decision in Amada Sanjuan v. School District of West New York reaffirms the broad discretion arbitrators possess in determining appropriate penalties for conduct unbecoming by tenured employees. This ruling highlights the importance of considering the totality of circumstances and the individual’s service record in tenure disputes.

If you have any questions regarding this New Jersey Supreme Court decision or need representation, please call the Bianchi Law Group, LLC and our team of Former Prosecutors at 862-225-1965. We are here to provide expert legal assistance and guidance.