State v. Nakaneula

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This labor dispute arose out of a negotiation between the State and other governmental entities (collectively, the State) and United Public Workers (UPW) regarding the renewal and modification of a collective bargaining agreement. The State and UPW failed to reach an agreement, and the case proceeded to arbitration. Because the parties were unable to select a neutral arbitrator, the Hawai’i Labor Relations Board (HLRB) ordered the American Arbitration Association to select the neutral arbitrator. Both parties challenged the actions of the HLRB. The circuit court affirmed the HLRB’s rulings. On appeal, UPW asserted that the circuit court had jurisdiction to resolve the dispute regarding the selection of the arbitrator. The Intermediate Court of Appeals disagreed, determining that HLRB had exclusive original jurisdiction under Haw. Rev. Stat. 89-14. UPW appealed, arguing that the circuit court had jurisdiction over the dispute regarding selection of the arbitrator under Haw. Rev. Stat. 658A. The Supreme Court affirmed, holding (1) the HLRB had jurisdiction to resolve the dispute over the selection of the arbitrator under chapter 89, as the arbitration was required by statute as part of the legislatively mandated process for resolving impasses in collective bargaining; and (2) chapter 658A was not applicable to this case. View "State v. Nakaneula" on Justia Law