Wash. Court of Appeals published opinion — 315223.cor.pdf

example. If an employee was seeking only that earned pay but not challenging any loss

flowing from the nonrenewal of her employment, she would appear to state an arbitrable

gnevance. Here, by contrast, the only remedy requested by the union's initial and

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No. 31522-3-111
Spokane Sch. Dist. No. 81 v. Spokane Educ. Ass 'n

amended grievances on behalf of Ms. Easterling is an arbitrator-ordered additional year

of provisional status. When asked at oral argument whether an arbitrator-ordered year of

employment would not undermine the negotiated limitation on arbitration of nonrenewal,

the union's lawyer responded that perhaps the arbitrator could instead award damages

equal to the salary and benefits that Ms. Easterling would have earned from that

additional year of employment. Yet that, too, would undermine the parties' negotiated

limitation on arbitration.

A CBA is a contract, whose construction is governed by ordinary principles of

contract law. See Barclay v. City o/Spokane, 83 Wn.2d 698, 700, 521 P.2d 937 (1974);

Kitsap County Deputy Sheriff's Guildv. Kitsap County, 148 Wn. App. 907, 910, 201 P.3d

396 (2009) (citing Barclay, 83 Wn.2d at 700). One such principle is that an interpretation

that gives a reasonable, fair, just, and effective meaning to all manifestations of intention

is preferred to an interpretation that leaves a part of such manifestations unreasonable,

imprudent, or meaningless. Pub. Uti!. Dist. No.1 0/Lewis County v. Wash. Pub. Power

Supply Sys., 104 Wn.2d 353,373, 705 P.2d 1195,713 P.2d 1109 (1985). Another is that

we will not give effect to an interpretation that would render contractual obligations