School District Township Millcreek v. Millcreek Education Association and Pennsylvania Labor Relations Board

for the bargaining unit consisting of "teachers, traveling teachers, guidance counselors, librarians, traveling librarian, dental hygienist, speech therapists, and nurses" employed by the School District of Millcreek Township (School District). The Union and the School District thereafter negotiated several collective bargaining agreements without changing the description of the bargaining unit. At the time that the PLRB certified the bargaining unit, the School District employed "long term substitute teachers" to fill the positions of teachers who were on leaves of absence extending beyond 89 days.