A tenured teacher who was laid off due to budget cuts brought an action in Superior Court against her board of education for breach of contract. The court held that an individual employee lacked standing to enforce the provisions of a collective bargaining agreement, unless the Union had first breached its duty of fair representation.

The court found that the teacher lacked standing to enforce the contractual provision that required the school district to lay off other teachers first. Having failed to engage the union in her dispute, and failing to allege and prove a breach of its duty of fair representation, the teacher’s claim failed as the court granted summary judgment on behalf of the board of education.