Where the teachers union failed to offer sufficient evidence that board of education could have implemented alternative procedures instead of laying off teachers due to budget shortfall, district court did not err in granting summary judgment to board.The 7th U.S. Circuit Court of Appeals affirmed a decision by Judge Jorge L. Alonso, Northern District of Illinois.During the 2010-11 school year, the Board of Education of the city of Chicago concluded that it would need to eliminate certain teaching and paraprofessional …