Portage County Board of Developmental Disabilities

First Amendment—Freedom of speech—Picketing in connection with a labor-relations dispute—R.C. 4117.11(B)(7)'s prohibition against inducing or encouraging any individual in connection with a labor-relations dispute to picket the residence or place of private employment of any public official or representative of the public employer violates the First Amendment to the United States Constitution as a content-based restriction of expressive activity—Court of appeals' judgment affirmed.

CONSTITUTIONAL LAW - First Amendment to the United States Constitution Ohio Constitution, Article I, Section 11 free speech State Employment Relations Board Public Employees Collective Bargaining Act R.C. 4117.11(B)(7) unfair labor practice labor relations dispute employee organization induce or encourage picketing residence or place of private employment representative of the public employer unconstitutional restriction on speech public forum content-based strict scrutiny not necessary to serve a compelling state interest protect residential privacy preserve labor peace encourage public service not narrowly tailored not the least restrictive means prohibits lawful conduct secondary picketing distinction between lawful and unlawful secondary activity based on picketer's conduct and objective.

CIVIL - arbitration exceed authority language of the agreement ambiguous extrinsic evidence employee's favor application to vacate upheld construed in context of the evidence drawn from the essence of the agreement no error in confirming award.

ARBITRATION - collective bargaining agreement unilateral change in job description beyond scope of job description appeal to trial court trial court found arbitrator exceeded his authority and vacated award R.C. 2711.10 de novo review of trial court's decision, not abuse of discretion trial court is limited to determining whether there is a rational nexus between the CBA and the award trial court erred in imposing its interpretation of the CBA in place of the arbitrator's.