Detroit Police Officers Ass'n. v. City of Detroit

214 N.W.2d 803, 391 Mich. 44, 1974 Mich. LEXIS 123, 85 L.R.R.M. (BNA) 2536
CourtMichigan Supreme Court
DecidedFebruary 14, 1974
Docket13 September Term 1973, Docket Nos. 54,410, 54,411
StatusPublished
Cited by198 cases

This text of 214 N.W.2d 803 (Detroit Police Officers Ass'n. v. City of Detroit) is published on Counsel Stack Legal Research, covering Michigan Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Detroit Police Officers Ass'n. v. City of Detroit, 214 N.W.2d 803, 391 Mich. 44, 1974 Mich. LEXIS 123, 85 L.R.R.M. (BNA) 2536 (Mich. 1974).

Opinion

Swainson, J.

In 1965, the Legislature passed *50 1965 PA 379 1 which amended the public employment relations act (PERA) to allow public employees 2 to select a collective bargaining representative and to enter into collective bargaining negotiations with their public employer. Pursuant to the newly amended PERA the Detroit Police Officers Association (DPOA) gained recognition as the exclusive collective bargaining agent for a unit of Detroit patrolmen and policewomen in January of 1966. Shortly thereafter, extensive collective bargaining negotiations proceeded between the City of Detroit (City) and the DPOA.

The collective bargaining negotiations continued until 1968 without resolving several areas of disagreement. The DPOA in July of 1968 filed an unfair labor practices charge 3 with the Labor Mediation Board, later redesignated the Michigan Employment Relations Commission, (MERC) alleging that the City had refused to bargain in good faith on key issues. A hearing was held and MERC issued a decision and order on March 18, 1971 addressing the issues raised by the DPOA. City of Detroit, Police Department, 6 MERC Lab Op 237 (1971). The conclusions of MERC on the issues relevant to today’s appeal can be summarized as follows:

1. The adoption of the residency ordinance did not remove the subject of a residency requirement for police officers from the arena of collective bargaining. However, the City did not commit an unfair labor practice by enacting the residency ordinance. A valid impasse was reached when the common council rejected the agreement reached between the DPOA and the City’s bargaining *51 team. Thereafter, the City was free to take unilateral action.
2. The City is not required to bargain over recruiting requirements for patrolmen. The duty to bargain extends only to those "terms and conditions of employment” that affect employees after they have commenced their employment relationship.
3. The City erroneously refused to bargain on changes in the police retirement plan when it initiated and conducted a voter referendum to amend the City Charter provisions controlling the police retirement plan. MERC ordered, on this issue, "that the City of Detroit shall not require as a condition to any agreement reached regarding retirement provisions for police officers that [such agreement] be approved by a vote of the electorate.”

The City appealed that portion of MERC’s decision dealing with the residency requirement and pension provisions to the Court of Appeals. Detroit Police Officers Association v Detroit, 41 Mich App 723; 200 NW2d 722 (1972). The Court of Appeals reversed MERC on the residency issue interpreting this Court’s decision in Detroit Police Officers Association v Detroit, 385 Mich 519; 190 NW2d 97 (1971), to hold that because the City could constitutionally impose the residency ordinance it was no longer obligated to bargain with regard to this subject. On the retirement issue, the Court of Appeals agreed with MERC that the duty to bargain under the provisions of PERA concerning retirement plan changes prevailed over any contrary provision in the City Charter.

After the decision of the Court of Appeals was issued, both the DPOA and the City — sought leave to appeal to this Court. Leave was granted, 388 *52 Mich 807 (1972). Phrased in the language of labor law, the parties seek basically to have two questions answered.

1. Does the City of Detroit have the duty under PERA to sbargain in good faith with the DPOA regarding residency requirements for police officers? If so, did the City violate its duty to bargain in good faith when it enacted the residency ordinance?

2. Does the City have a duty under PERA to bargain in good faith with the DPOA on the subject of police retirement plan changes where retirement provisions are a part of the City Charter and amendable only by a popular vote of the electorate?

Before turning to consider the specific issues presented, we find it useful to examine in general terms the meaning of the duty to bargain under PERA and especially § 15 (MCLA 423.215; MSA 17.455[15]) thereof.

The legislative parameters of the duty to bargain under PERA are found in § 15, which reads:

"A public employer shall bargain collectively with the representatives of its employees as defined in section 11 and is authorized to make and enter into collective bargaining agreements with such representatives. For the purposes of this section, to bargain collectively is the performance of the mutual obligation of the employer and the representative of the employees to meet at reasonable times and confer in good faith with respect to wages, hours, and other terms and conditions of employment, or the negotiation of an agreement, or any question arising thereunder, and the execution of a written contract, ordinance or resolution incorporating any agreement reached if requested by either party, but such obligation does not compel either party to agree to a proposal or require the making of a concession.”

*53 Section 15 of PERA undoubtedly was patterned after § 8(d) of the National Labor Relations Act (NLRA). 4 5Both statutes use almost identical language in describing the duty to bargain. The decision by the Michigan Legislature to adopt the language of § 8(d) of the NLRA is significant. Section 8(d) has been a part of the NLRA since the Taft-Hartley amendments of 1947. 5 The terms of § 8(d) have been litigated in numerous cases before the National Labor Relations Board (NLRB) and' the Federal courts. Although we cannot state with certainty, it is probably safe to assume that the Michigan Legislature intentionally adopted § 15 PERA in the form that it did with the expectation that MERC and the Michigan courts would rely on the legal precedents developed under NLRA, § 8(d) to the extent that they apply to public sector bargaining. Edwards, The Emerging Duty to Bargain in the Public Sector, 71 Mich L Rev 885, 895 (1973).

The primary obligation placed upon the parties in a collective bargaining setting is to meet and confer in good faith. The exact meaning of the duty to bargain in good faith has not been rigidly defined in the case law. Rather, the courts look to the overall conduct of a party to determine if it has actively engaged in the bargaining process *54 with an open mind and a sincere desire to reach an agreement. National Labor Relations Board v Montgomery Ward & Co, 133 F2d 676, 686; 146 ALR 1045 (CA 9, 1943); National Labor Relations Board v General Electric Co, 418 F2d 736, 756 (CA 2, 1969); cert den 397 US 965 (1970); Morris, Ed, The Developing Labor Law, ch 11, (1971).

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214 N.W.2d 803, 391 Mich. 44, 1974 Mich. LEXIS 123, 85 L.R.R.M. (BNA) 2536, Counsel Stack Legal Research, https://law.counselstack.com/opinion/detroit-police-officers-assn-v-city-of-detroit-mich-1974.