2008 merc update

2008 MERC UPDATE2008 MERC UPDATE

2008 Bargaining, Political 2008 Bargaining, Political Action and PR ConferenceAction and PR Conference

Douglas V. WilcoxDouglas V. WilcoxMEA Staff AttorneyMEA Staff Attorney

INTRODUCTIONINTRODUCTION

MERC is part of the Department of Labor MERC is part of the Department of Labor and Economic Growth and Economic Growth

MERC Jurisdiction:MERC Jurisdiction: all public employers all public employers except civil service employees and except civil service employees and Michigan Supreme Court employeesMichigan Supreme Court employees

MERC ENFORCES 3 LAWSMERC ENFORCES 3 LAWS

Public Employment Relations Act Public Employment Relations Act

Labor Relations and Mediation Act Labor Relations and Mediation Act

Compulsory Arbitration Act Compulsory Arbitration Act

MERC FUNCTIONSMERC FUNCTIONS

Appoints mediators, arbitrators and fact Appoints mediators, arbitrators and fact findersfinders

Conducts union representation electionsConducts union representation elections Determines appropriate bargaining unitsDetermines appropriate bargaining units Adjudicates ULP casesAdjudicates ULP cases

THE GRANHOLM THE GRANHOLM COMMISSIONERSCOMMISSIONERS

Christine A. Derdarian (D)Christine A. Derdarian (D) Nino Green (D) Nino Green (D) Eugene Lumberg (R)Eugene Lumberg (R)

Appointed by Governor for 3-year Appointed by Governor for 3-year staggered termsstaggered terms

ADMINISTRATIVE LAW ADMINISTRATIVE LAW JUDGESJUDGES

3 ALJs3 ALJs David PeltzDavid Peltz Doyle O’ConnorDoyle O’Connor Julia SternJulia Stern

Cases are very backed upCases are very backed up!!

CASE SUMMARIESCASE SUMMARIES

108 Cases Issued in 2007!108 Cases Issued in 2007!

39 Case Summaries in Outline39 Case Summaries in Outline

Representation CasesRepresentation Cases

MERC has exclusive jurisdiction to MERC has exclusive jurisdiction to determine appropriate bargaining unitdetermine appropriate bargaining unit

COMMONLY LITIGATED AREASCOMMONLY LITIGATED AREAS Managerial/ExecutiveManagerial/Executive ConfidentialConfidential SupervisorySupervisory Community of InterestCommunity of Interest

Managerial EmployeesManagerial Employees

DEFINITIONDEFINITION Policy-making head of a major department Policy-making head of a major department Formulates, determines and effectuates Formulates, determines and effectuates

management policy on employer-wide management policy on employer-wide basisbasis

Confidential EmployeesConfidential Employees

DEFINITIONDEFINITION Acts in a confidential capacity to one who Acts in a confidential capacity to one who

formulates, determines and effectuates formulates, determines and effectuates management policy regarding labor management policy regarding labor relationsrelations

Employer gets 1 confidential employeeEmployer gets 1 confidential employee Employer has burden to show the need for Employer has burden to show the need for

additional confidential employeesadditional confidential employees

Supervisory EmployeesSupervisory Employees

DEFINITIONDEFINITION Authority, in the interest of the employer, Authority, in the interest of the employer,

to hire and fire . . . adjust grievances, or to hire and fire . . . adjust grievances, or effectively recommend such actioneffectively recommend such action

Requires independent judgmentRequires independent judgment Lead workers are not supervisorsLead workers are not supervisors

Sporadic authority not enoughSporadic authority not enough

Community of Interest FactorsCommunity of Interest Factors

Job dutiesJob duties SkillsSkills Education and Education and

trainingtraining Working Working

conditionsconditions

Supervisory Supervisory hierarchyhierarchy

Centralized labor Centralized labor relationsrelations

Physical location Physical location of employeesof employees

Pay differentialsPay differentials

Goodrich Area School (p __)Goodrich Area School (p __)

SUPERVISOR CASESUPERVISOR CASE Union filed ULP/UC because district Union filed ULP/UC because district

removed custodial supervisor from unit removed custodial supervisor from unit MERCMERC Custodial Supervisor was a SupervisorCustodial Supervisor was a Supervisor Responsible for discipline and evaluationResponsible for discipline and evaluation Authority to hire or effectively recommend Authority to hire or effectively recommend

hiringhiring

Garden City Schools (p __)Garden City Schools (p __) TEAMSTERS SOUGHT TO REPLACE MEATEAMSTERS SOUGHT TO REPLACE MEA ISSUE ISSUE Whether employees who are not actively employed Whether employees who are not actively employed

may vote in the election?may vote in the election? TESTTEST Is there a reasonable expectation of recall based on Is there a reasonable expectation of recall based on

the surrounding circumstances and future plans of the surrounding circumstances and future plans of the employer?the employer?

MERCMERC Custodial and cafeteria services were subcontracted Custodial and cafeteria services were subcontracted

and there was no objective basis to conclude the and there was no objective basis to conclude the district would change its mind in the futuredistrict would change its mind in the future

Chippewa County (p )Chippewa County (p )

DECERTIFICATION AND TA’sDECERTIFICATION AND TA’s Parties reached TA on April 7Parties reached TA on April 7 Union ratifiedUnion ratified County set to ratify on May 10County set to ratify on May 10 May 5: decertification petition filedMay 5: decertification petition filed County refused to ratify Union filed ULPCounty refused to ratify Union filed ULP

Refusal to ratify within 30 days = bad faith bargainingRefusal to ratify within 30 days = bad faith bargaining MERCMERC County did not violate the ActCounty did not violate the Act

Chippewa County (p )Chippewa County (p ) Court of AppealsCourt of Appeals Duty to bargain requires party to act Duty to bargain requires party to act

expeditiously and decisively to accept/reject TAexpeditiously and decisively to accept/reject TA County did not violate Act by delaying its County did not violate Act by delaying its

ratification vote because there was no evidence ratification vote because there was no evidence of bad faithof bad faith

RULE: Decertification petition is barred RULE: Decertification petition is barred pending subsequent action on the TA for 30 pending subsequent action on the TA for 30 days after TA is reacheddays after TA is reached

Court remanded case and County was ordered Court remanded case and County was ordered to vote on TA within 30 daysto vote on TA within 30 days

ULP CasesULP Cases

4 BASIC ULPs AGAINST EMPLOYERS4 BASIC ULPs AGAINST EMPLOYERS Interference with, restraint or coercion of Interference with, restraint or coercion of

public employeespublic employees Assistance, domination or interference Assistance, domination or interference

with a labor organizationwith a labor organization Discrimination against public employeesDiscrimination against public employees Refusal to bargain in good faithRefusal to bargain in good faith

Interference, Restraint or Interference, Restraint or Coercion of Public EmployeesCoercion of Public Employees

SECTION 9 RIGHTSSECTION 9 RIGHTS Organize together or to form, join or assist Organize together or to form, join or assist

in labor organizationsin labor organizations Engage in lawful concerted activities for Engage in lawful concerted activities for

purpose of collective bargaining or other purpose of collective bargaining or other mutual aid and protectionmutual aid and protection

Bargain collectively with the employer Bargain collectively with the employer through representatives of their own free through representatives of their own free choicechoice

Examples of Protected Examples of Protected Concerted ActivityConcerted Activity

Lawful picketing or leafletting Lawful picketing or leafletting Organizing activitiesOrganizing activities Speaking on behalf of other employees Speaking on behalf of other employees

about wages, hours and working about wages, hours and working conditionsconditions

Other activity designed to benefit more Other activity designed to benefit more than one employeethan one employee

Conduct Which Interferes With, Conduct Which Interferes With, Restrains or CoercesRestrains or Coerces

Denying union representation to membersDenying union representation to members Polling employees to determine views on Polling employees to determine views on

bargaining topicsbargaining topics Retaliation for filing grievanceRetaliation for filing grievance Retaliation because of status as union Retaliation because of status as union

member or officermember or officer Surveillance of or threats to employeesSurveillance of or threats to employees

City of Detroit (p __)City of Detroit (p __)

COP SUSPENDED FOR CREATING COP SUSPENDED FOR CREATING WEBSITE WHILE OFF-DUTYWEBSITE WHILE OFF-DUTY

Website was a forum to express concerns Website was a forum to express concerns about department issuesabout department issues

Website included info on salaries, Website included info on salaries, equipment, staffing, grievances, union equipment, staffing, grievances, union elections, comic reliefelections, comic relief

Media published storiesMedia published stories Police chief said he thought site was finePolice chief said he thought site was fine


7 MONTHS LATER7 MONTHS LATER Chief suspended cop w/ payChief suspended cop w/ pay Website contained racial slursWebsite contained racial slurs If website is not shutdown, cop will be If website is not shutdown, cop will be

suspended without paysuspended without pay


MERCMERC Case of first impressionCase of first impression Operation of website = protected activity Operation of website = protected activity

Pay, promotions, manpower, disciplinePay, promotions, manpower, discipline Ancillary activity did not deprive cop of PERA Ancillary activity did not deprive cop of PERA

protectionprotection No adverse impact on department or public No adverse impact on department or public

confidenceconfidence COURTOF APPEALS AGREED WITH MERCCOURTOF APPEALS AGREED WITH MERC

Assistance, Domination or Assistance, Domination or Interference with UnionInterference with Union

DOMINATIONDOMINATION Supervisors included in non-supervisory Supervisors included in non-supervisory

unitunit ASSISTANCE TO UNIONASSISTANCE TO UNION Employer can’t assist one union over Employer can’t assist one union over

anotheranother If there is a question concerning If there is a question concerning

representation, employer must stop representation, employer must stop bargaining with incumbent unionbargaining with incumbent union

Assistance, Domination or Assistance, Domination or Interference with UnionInterference with Union

INTERFERENCE WITH UNIONINTERFERENCE WITH UNION Communicating with members to degrade Communicating with members to degrade

or bypass unionor bypass union Encouraging decertification effortsEncouraging decertification efforts Conduct that drives a wedge between Conduct that drives a wedge between

union and its membersunion and its members

Discrimination Against Discrimination Against EmployeesEmployees

Unlawful to discriminate in regard to Unlawful to discriminate in regard to hire, terms or other employment hire, terms or other employment conditions in order to encourage or conditions in order to encourage or discourage union membershipdiscourage union membership

Focus is on Focus is on employer’semployer’s motivemotive


UNLAWFUL CONDUCTUNLAWFUL CONDUCT Discipline and discharge Discipline and discharge motivatedmotivated by by

anti-union animusanti-union animus Pay different wages Pay different wages Transfer or reassign employee Transfer or reassign employee Layoff or fail to recall employeeLayoff or fail to recall employee


Discrimination for Testifying or Discrimination for Testifying or Instituting Proceedings under the ActInstituting Proceedings under the Act

Employer’s aren’t usually this dumbEmployer’s aren’t usually this dumb Actual participation is not requiredActual participation is not required


DUAL MOTIVE TESTDUAL MOTIVE TEST Union must show union activity was Union must show union activity was aa

motivating factormotivating factor Employer must show it would have made Employer must show it would have made

the same decision in the absence of the same decision in the absence of protected conductprotected conduct

Utica Community Schools (p __)Utica Community Schools (p __)

DISTRICT RETALIATED AGAINST MEMBER DISTRICT RETALIATED AGAINST MEMBER Max teaching load = 155 students Max teaching load = 155 students Complaints about imbalance in class sizesComplaints about imbalance in class sizes Member met with district to discuss issueMember met with district to discuss issue Principal said the problem could be solved if Principal said the problem could be solved if

member was put back in classroom full-timemember was put back in classroom full-time Union grieved the class size issueUnion grieved the class size issue Member was transferred and lost assignmentMember was transferred and lost assignment


MERCMERC Member engaged in protected activityMember engaged in protected activity

Principal knew member was leading union Principal knew member was leading union effortsefforts

Anti-union animus established through Anti-union animus established through principal’s conductprincipal’s conduct Proposed to eliminate member’s jobProposed to eliminate member’s job Anger toward union and memberAnger toward union and member


MERCMERC Anti-union animus was a motivating factor Anti-union animus was a motivating factor

in decision to eliminate member’s jobin decision to eliminate member’s job District ordered to reinstate member to District ordered to reinstate member to

prior assignments and make her wholeprior assignments and make her whole

City of Bay City (p __)City of Bay City (p __)

ILLEGAL CITY RESOLUTIONILLEGAL CITY RESOLUTION Resolution:Resolution: Employees could only address Employees could only address

city commissioners on issues outside of city commissioners on issues outside of labor relationslabor relations

ULP on interference with organizing ULP on interference with organizing campaigncampaign

Months before ULP hearing, member talked Months before ULP hearing, member talked to a commissioner about its organizational to a commissioner about its organizational chart and was subsequently warnedchart and was subsequently warned


Day of ULP hearing, member spoke Day of ULP hearing, member spoke with another commissioner about city with another commissioner about city manager’s involvement in the ULPmanager’s involvement in the ULP

Member was suspended Union argued Member was suspended Union argued resolution restrained employees from resolution restrained employees from engaging in protected activityengaging in protected activity

ALJALJ No jurisdiction over constitutional law No jurisdiction over constitutional law

issuesissues


MERCMERC Employees’ right to communicate Employees’ right to communicate

about employment conditions is about employment conditions is inherent in the right to self-organizeinherent in the right to self-organize

This right extends to employees, non-This right extends to employees, non-employees and employer officialsemployees and employer officials

Resolution had chilling effect on Resolution had chilling effect on Section 9 rights and was unlawful Section 9 rights and was unlawful

Warren Consolidated Schools (p __)Warren Consolidated Schools (p __)

DISCIPLINE AND SUSPICIOUS TIMINGDISCIPLINE AND SUSPICIOUS TIMING Teacher and board member were rivalsTeacher and board member were rivals Teacher required students to attend board Teacher required students to attend board

meetingmeeting Board member made unflattering Board member made unflattering

comments about teachercomments about teacher Teacher and administration reviewed tapeTeacher and administration reviewed tape

Teacher said “are you on steroids”Teacher said “are you on steroids” Board member threw tape at teacherBoard member threw tape at teacher

Warren Consolidated Schools (p )Warren Consolidated Schools (p )

Complaints and grievances filedComplaints and grievances filed Before grievance meeting, board member Before grievance meeting, board member

said teacher accused him of steroid use in said teacher accused him of steroid use in pastpast

District decided to investigateDistrict decided to investigate After subsequent grievance meeting, teacher After subsequent grievance meeting, teacher

disciplineddisciplined

Warren Consolidated Schools (p )Warren Consolidated Schools (p )

ALJ Found Anti-Union Animus ALJ Found Anti-Union Animus suspicious timing of district’s decision to suspicious timing of district’s decision to

investigate prior statementsinvestigate prior statements irregularity of investigationirregularity of investigation 4 month delay in disciplining teacher4 month delay in disciplining teacher failure to inform teacher of right to union failure to inform teacher of right to union

representationrepresentation decision to reprimand teacher at grievance decision to reprimand teacher at grievance

meetingmeeting

Warren Consolidated Schools (p__)Warren Consolidated Schools (p__)

MERC – No ULPMERC – No ULP Coincidental timing alone was not enoughCoincidental timing alone was not enough District gave reasonable explanation for delayDistrict gave reasonable explanation for delay Court of Appeals ReversedCourt of Appeals Reversed MERC failed to defer to ALJ on issues of witness MERC failed to defer to ALJ on issues of witness

credibilitycredibility MERC disregarded ALJ’s assessment of UD’s MERC disregarded ALJ’s assessment of UD’s

testimony about events leading to the reprimandtestimony about events leading to the reprimand MERC may not substitute its own credibility MERC may not substitute its own credibility

determinationsdeterminations

Ingham County (p __)Ingham County (p __)

WORK RULE WAS LEGITIMATEWORK RULE WAS LEGITIMATE Internal rule prohibiting release of Internal rule prohibiting release of

department documents to publicdepartment documents to public Union officer received memo about off-Union officer received memo about off-

duty detectives wearing pagers duty detectives wearing pagers Officer gave memo to its legal counsel Officer gave memo to its legal counsel Officer disciplinedOfficer disciplined

Ingham County (p__)Ingham County (p__)

ALJALJ Discipline adversely impacted right to Discipline adversely impacted right to

engage in protected activityengage in protected activity No legitimate interest in preventing No legitimate interest in preventing

unauthorized disclosure of confidential unauthorized disclosure of confidential information to publicinformation to public

Ingham County (p __)Ingham County (p __)

MERC AgreedMERC Agreed Employer may maintain a legitimate Employer may maintain a legitimate

business interest to prevent unauthorized business interest to prevent unauthorized disclosure of confidential informationdisclosure of confidential information

But there was no justification to prohibit But there was no justification to prohibit union president from giving legal counsel a union president from giving legal counsel a memo regarding employment conditionsmemo regarding employment conditions

Ingham County (p __)Ingham County (p __) COURT OF APPEALS REVERSEDCOURT OF APPEALS REVERSED Employer’s action did not adversely affect or Employer’s action did not adversely affect or

unreasonably restrict the union officer’s unreasonably restrict the union officer’s protected right to engage in lawful activityprotected right to engage in lawful activity

The officer was disciplined for violating job rules The officer was disciplined for violating job rules not because of her position as a union officialnot because of her position as a union official

Employer’s interest in keeping all internal Employer’s interest in keeping all internal documents out of the public outweighed the documents out of the public outweighed the union’s protected activityunion’s protected activity

Refusal to Bargain ULPsRefusal to Bargain ULPs

Unlawful for Employer to refuse to bargain Unlawful for Employer to refuse to bargain collectively with union representativescollectively with union representatives

ISSUESISSUES Bad faithBad faith RepudiationRepudiation Unilateral changes in employment conditions Unilateral changes in employment conditions ImpasseImpasse Duty to provide informationDuty to provide information

Wayne County Community Wayne County Community College (p __)College (p __)

CONTRACT REPUDIATIONCONTRACT REPUDIATION CBA required College to pay premiums for CBA required College to pay premiums for

3 health care plans (HAP, BCBS an PPO)3 health care plans (HAP, BCBS an PPO) College unilaterally reduced plans from 3 College unilaterally reduced plans from 3

to 2 to 2 Union protested and demanded to bargainUnion protested and demanded to bargain College failed to replyCollege failed to reply


Elements of Contract RepudiationElements of Contract Repudiation Contract breach is substantialContract breach is substantial Contract breach must have a significant Contract breach must have a significant

impact on the bargaining unitimpact on the bargaining unit No bona fide dispute over interpretation of No bona fide dispute over interpretation of

contract contract


MERC MERC College repudiated CBA by withdrawing College repudiated CBA by withdrawing

one of the health care plan options without one of the health care plan options without bargainingbargaining


EFFECTS BARGAININGEFFECTS BARGAINING College identified several jobs for College identified several jobs for

eliminationelimination Union requested to discuss impact Union requested to discuss impact After additional meetings, the union After additional meetings, the union

demanded to bargain the impact of the demanded to bargain the impact of the “proposed alignment” on various issues“proposed alignment” on various issues Combining of programs; assigning unit work Combining of programs; assigning unit work

to non-members and reducing working hoursto non-members and reducing working hours


MERCMERC Impact of reorganization was a mandatory topicImpact of reorganization was a mandatory topic Union not aware of any changes that took place Union not aware of any changes that took place

as a result of the layoff and reassignmentas a result of the layoff and reassignment The union demanded effects bargaining as soon The union demanded effects bargaining as soon

at it learned of changes at it learned of changes College failed to satisfy its bargaining obligationCollege failed to satisfy its bargaining obligation Back pay remedy issued Back pay remedy issued

Washtenaw County Road Washtenaw County Road Commission (p __)Commission (p __)

REFUSING TO ACCEPT GRIEVANCEREFUSING TO ACCEPT GRIEVANCE Union filed grievance Union filed grievance Identified specific article involving FMLAIdentified specific article involving FMLA County refused to accept grievance or County refused to accept grievance or

acknowledge it because the grievance acknowledge it because the grievance “failed to state a specific violation and “failed to state a specific violation and therefore is not a proper grievance”therefore is not a proper grievance”

Washtenaw County Road Washtenaw County Road Commission (p __)Commission (p __)

MERC MERC Employer violated Act because it cannot Employer violated Act because it cannot

refuse to process a grievance simply refuse to process a grievance simply because it believes the grievance lacks because it believes the grievance lacks meritmerit

Michigan Tech University (p )Michigan Tech University (p )

MAINTAINING STATUS QUO WHILE MAINTAINING STATUS QUO WHILE BARGAININGBARGAINING

Union certified to represent facultyUnion certified to represent faculty ULP filed for implementing merit-pay ULP filed for implementing merit-pay

systemsystem Decertification petition filedDecertification petition filed ULP amended because University granted ULP amended because University granted

salary increase which contributed to the salary increase which contributed to the decertification petition being fileddecertification petition being filed


General Rules Re: Status QuoGeneral Rules Re: Status Quo Amount of salary increase, whether Amount of salary increase, whether

across-the-board or merit-based, is a across-the-board or merit-based, is a mandatory topicmandatory topic

Refusal to give wage increase during Refusal to give wage increase during bargaining may be a ULP when those bargaining may be a ULP when those increases have become a condition of increases have become a condition of employmentemployment


ALJALJ Union had right to bargain over all aspects of Union had right to bargain over all aspects of

salary increase not controlled by past practicesalary increase not controlled by past practice University’s implementation of salary increases University’s implementation of salary increases

violated its duty to bargain in good faithviolated its duty to bargain in good faith Decertification petition dismissed because Decertification petition dismissed because

University illegally implemented salary increase University illegally implemented salary increase before petition was filedbefore petition was filed

Midland Public Schools (p )Midland Public Schools (p )

REFUSAL TO PROVIDE INFORMATIONREFUSAL TO PROVIDE INFORMATION District eliminated “handyman” District eliminated “handyman”

classification and transferred member to classification and transferred member to lower paying job, and union filed grievancelower paying job, and union filed grievance

Union asked for personal contracts for Union asked for personal contracts for nine specific individualsnine specific individuals

Information was consistent with union’s Information was consistent with union’s theory of case theory of case

District claimed info was not relevant District claimed info was not relevant


Union made a second requestUnion made a second request District refused and said to make a FOIA requestDistrict refused and said to make a FOIA request Union made a FOIA requestUnion made a FOIA request District charged Union $70 and only provided District charged Union $70 and only provided

some informationsome information Union demanded to bargain over the impact of Union demanded to bargain over the impact of

the job eliminationthe job elimination District only met briefly with the union and District only met briefly with the union and

rejected its proposalrejected its proposal


ALJALJ District violated Act by:District violated Act by:

Falsely asserted information did not existFalsely asserted information did not exist Requiring Union to use FOIA and not PERARequiring Union to use FOIA and not PERA Charging Union $10 per page for documentsCharging Union $10 per page for documents Withholding much of requested informationWithholding much of requested information Not approaching effects bargaining with an Not approaching effects bargaining with an

open mind open mind

DUTY OF FAIR DUTY OF FAIR REPRESENTATION CASESREPRESENTATION CASES

GENERAL RULEGENERAL RULE Serve interest of all members without Serve interest of all members without

hostility or discriminationhostility or discrimination Exercise discretion in complete good faith Exercise discretion in complete good faith

and honestyand honesty Avoid arbitrary conductAvoid arbitrary conduct

MSU Administrative-Professional MSU Administrative-Professional Association (p __)Association (p __)

REFUSING TO ARBITRATE REFUSING TO ARBITRATE GRIEVANCEGRIEVANCE

Member claimed union violated DFR by Member claimed union violated DFR by refusing to arbitrate his case and provide refusing to arbitrate his case and provide him with certain informationhim with certain information

Member was given opportunity to appear Member was given opportunity to appear before the Union’s and the MEA’s before the Union’s and the MEA’s Executive CommitteeExecutive Committee

MSU Administrative-Professional MSU Administrative-Professional Association (p __)Association (p __)

ALJALJ No DFR breach No DFR breach Union acted reasonableUnion acted reasonable Member has no right to demand arbitration of grievance Member has no right to demand arbitration of grievance Union has discretion and may weigh several factors:Union has discretion and may weigh several factors:

Burden on grievance machineryBurden on grievance machinery Amount at stakeAmount at stake Likelihood of successLikelihood of success CostCost Desirability of winningDesirability of winning

Sault Ste Marie (p )Sault Ste Marie (p ) UNION INVITED BOARD MEMBERS TO ATTEND UNION INVITED BOARD MEMBERS TO ATTEND

BARGAININGBARGAINING ALJALJ An employer’s attempt to bypass the union and deal An employer’s attempt to bypass the union and deal

directly with employees undermines the union’s authority directly with employees undermines the union’s authority as bargaining representativeas bargaining representative

Governing body of public employer does not stand in the Governing body of public employer does not stand in the same relation to its bargaining team as the employees same relation to its bargaining team as the employees do to their exclusive representativedo to their exclusive representative

Thus, the union’s effort to bargain directly with the school Thus, the union’s effort to bargain directly with the school board was not unlawfulboard was not unlawful

MERC WebsiteMERC Website

www.michigan.gov/ciswww.michigan.gov/cis Cases available from 1998 to presentCases available from 1998 to present

2008 MERC UPDATE2008 MERC UPDATE

The End!The End!

2008 merc update

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