In Bellflower Education Assn. v. Bellflower Unified School Dist. (1991) 228 Cal.App.3d 805, a probationary teacher who had not been reelected to employment filed a grievance, contending the district had deprived her of the chance to achieve tenure by failing to conduct her performance evaluations in accordance with the parties' collective bargaining agreement. An arbitrator found the district had violated the agreement -- the district in fact conceded it had not followed the evaluation procedures set forth in the agreement - and ordered the district to cease and desist from committing further violations. The arbitrator also ordered the teacher to be reinstated for an additional year on probationary status, during which she was to be evaluated in accordance with the procedures set forth in the parties' agreement. (Bellflower, supra, 228 Cal.App.3d at pp. 807-808.) The district petitioned to vacate the arbitrator's award, and the trial court granted the petition. The association appealed. Regarding the contention that the district had not followed the evaluation procedures in the parties' agreement, the appellate court noted that the article governing evaluation procedures in the parties' agreement was not applicable by its terms to nonreelection. As to the separate issue of the propriety of the remedy chosen by the arbitrator, reinstatement, the court noted that the agreement could not have purported to address nonreelection procedures because any such application would be preempted by the Government and Education Codes. (Bellflower, supra, 228 Cal.App.3d at pp. 811-812.) In contrast, the appellate court found that the "violation of bargained-for evaluation procedures is within the allowable scope of collective bargaining under the Government Code." (Id. at p. 812.) As to the reinstatement ordered by the arbitrator, the Bellflower court concluded that remedy was "beyond the scope of the arbitrator's powers under the Agreement . . . . Reinstatement would interfere with the District's exclusive right and statutory duty to dismiss probationary employees under applicable provisions of the Education Code, for any reason, without providing a statement of that reason and without the need for hearing and appeal from such decisions." (Id. at p. 812.) Conversely, the court found that "the arbitrator's order that the District cease and desist from conducting certificated employee evaluations in violation of the Agreement's evaluation procedures was within the scope of his authority and not in conflict with any applicable statutes." (Ibid.)