February 2015

Warren Consolidated Schools -and- Kathryn Combs, Dawn Stroud, and Glenn Hyatt

Unfair Labor Practice Not Found: Charging Parties Failed to Establish a Connection Between Union Member's Return to Full-Time Status and the Layoff of Psychologist Positions; The Efforts of a Union Member to Return to Full-Time Status Did Not Constitute Protected Concerted Activity; Charging Parties Failed to Allege Respondent Harbored Anti-Union Animus; Charging Parties Failed to Establish Prima Facie Case of Discrimination or Retaliation.

Anti-Union Animus; Discrimination; Retaliation; Protected Concerted Activity

Taylor School District -and- Taylor Federation of Teachers, AFT, Local 1085 -and- Nancy Rhatigan, Rebecca Metz and Angela Steffke

Unfair Labor Practice Found: Employer coerced and discriminated against bargaining unit members by entering into a ten-year Union Security Agreement; Union violated the duty of fair representation by entering into the ten-year agreement; The agreement compels bargaining unit members to either join or to financially support the Union.

Three Rivers Community Schools -and- Theresa Sussdorf -and- Michigan Education Association

Challenge to Tabulation of Election Results: Commission found that because Glen Carlson was an eligible voter, his ballot should be included with the tabulation of election results that originated from a decertification petition against the Incumbent Labor Organization.

Tri County Area Schools -and- Tri County Custodial/Maintenance Association, MEA/NEA

Unfair Labor Practice Not Found: Charging Party Failed to Establish a Prima Facie Case of Discrimination; Respondent had no Duty to Bargain Over Whether to Subcontract Bargaining Unit Work; Charging Party Failed to Demonstrate a Precondition to Bargaining in Violation of §10(1)(e); Charging Party Failed to Demonstrate That Anti-Union Animus was a Motivating Factor in Respondent's Decision to Subcontract Bargaining Unit Work; Charging Party Failed to Show Unequal Opportunity To Bid on Bargaining Unit Work; No Direct Dealing is Present When The Respondent's Statements Were Not Made for the Purpose of Establishing or Changing Wages, Hours and Terms and Conditions of Employment and are Not Made to Undercut the Union's Role in Bargaining.

Detroit Transportation Corporation -and- Michigan Association of Police -and- Vernon White

Unfair Labor Practice Not Found: Charging Party Failed to Allege Facts to Prove Union Acted Arbitrarily, Discriminatorily, or in Bad Faith; Employers Offer to Settle Grievance Reasonable; Charging Party Failed to State Claim upon which Relief can be Granted; Charging Party's Failure to Comply with Commission Rule 176 Warrants Dismissal of Charge.

Garden City Public Schools -and- Garden City Education Association, MEA/NEA

Unfair Labor Practice Found: Respondent Repudiated Collective Bargaining Agreement by Unilaterally Changing Health Insurance Plan; Interpretation of Contract Language was Not Disputed; Respondent's Change of Cost Sharing Options under 2011 PA 152 from Choice Indicated in the Parties' Collective Bargaining Agreement Violated its Duty to Bargain; Respondent Failed to Assert Any Disputed Material Facts that Supported its Defense to the Charge, Therefore Summary Disposition is Warranted.

Duty to Bargain; 2011 PA 152; 80% Employer Share Option; Repudiation; Good Faith Dispute; Unilateral Change; Permissive Subjects of Bargaining; Summary Disposition; Reconsideration

Michigan State Government
Department of Licensing and Regulatory Affairs 
Bureau of Employment Relations

This page last updated 3/10/2015