Missouri Corrections Officers Association, Inc. v. Missouri Office of Administration

CourtMissouri Court of Appeals
DecidedDecember 6, 2022
DocketWD84917
StatusPublished

This text of Missouri Corrections Officers Association, Inc. v. Missouri Office of Administration (Missouri Corrections Officers Association, Inc. v. Missouri Office of Administration) is published on Counsel Stack Legal Research, covering Missouri Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Missouri Corrections Officers Association, Inc. v. Missouri Office of Administration, (Mo. Ct. App. 2022).

Opinion

In the Missouri Court of Appeals Western District MISSOURI CORRECTIONS ) OFFICERS ASSOCIATION, INC., ET ) AL., ) WD84917 ) Respondents, ) OPINION FILED: ) December 6, 2022 v. ) ) MISSOURI OFFICE OF ) ADMINISTRATION, ET AL., ) ) Appellants. )

Appeal from the Circuit Court of Cole County, Missouri The Honorable Jon Edward Beetem, Judge

Before Division Four: Gary D. Witt, Chief Judge, Presiding, Mark D. Pfeiffer, Judge and Thomas N. Chapman, Judge

Missouri Office of Administration; Sarah Steelman1, Commissioner of the Office

of Administration, in her official capacity; and Stacy Neal, Director of the Division of

Accounting of the Office of Administration, in her official capacity (collectively, "OA")

appeal the judgment of the Circuit Court of Cole County ("trial court"), following a bench

1 We note that Sarah Steelman is no longer the Director of the Office of Administration and that position is currently held by Kenneth J. Zellers. However, no substitution of parties has been filed with the court and therefore Sarah Steelman remains a party in her former official capacity. trial, in favor of Missouri Corrections Officers Association, Inc., Terry Enberg, and Tina

Courtway (collectively, "MOCOA") on MOCOA's amended petition against OA. The trial

court issued findings of fact, conclusions of law, and judgment ("Judgment") finding that

the Emergency Rule and Final Rule (collectively, "Rules") issued by OA were

unconstitutional because they infringed on MOCOA's constitutional rights to organize and

to bargain collectively, freedoms of speech and association, and equal protection. The trial

court also found that OA's decisions in December 2019 to suspend payroll deduction and

in March 2020 to deny payroll deductions for MOCOA were unlawful, arbitrary,

capricious, and unreasonable. The trial court ordered OA to resume payroll deductions for

current Department of Corrections ("DOC") employees who were having MOCOA dues

deducted from their pay prior to OA's December 9, 2019, decision to suspend payroll

deduction, and the trial court ordered OA to accept new MOCOA payroll deduction

applications signed by DOC employees in the future.

OA raises nine points on appeal: OA argues the trial court erred in: (1) finding that

OA's December 2019 decision to discontinue MOCOA dues deduction was unlawful under

section 536.1502 because MOCOA did not meet the regulatory requirements for dues

deduction in that (a) it could not deduct dues as a labor union because it had no existing

labor agreement, (b) it could not deduct dues as an employee association because it was

not a "group of state employees," and (c) it could not deduct dues as an employee

association because 1 C.S.R. 10-3.010 (2019) does not permit labor unions to be employee

2 All statutory references are to Revised Statutes of Missouri (2016), as currently updated by supplement, unless otherwise indicated.

2 associations; (2) finding that OA's December 2019 decision to discontinue MOCOA's dues

deduction was arbitrary, capricious, and unreasonable under section 536.150 because 1

C.S.R. 10-3.010 (2019) required OA to deny dues deductions; (3) finding the Rules

violated article I, section 29 of the Missouri Constitution because the Rules did not violate

the right to bargain collectively; (4) finding the Rules violated article I, section 8 of the

Missouri Constitution because the Rules did not violate union-members' constitutional

right to free speech; (5) finding the Rules violated article I, section 9 of the Missouri

Constitution because the Rules did not violate union-members' right to freedom of

association; (6) finding the Rules violated article I, section 2 of the Missouri Constitution

because the Rules did not violate union-members' right to equal protection; (7) finding

OA's March 2020 decision denying MOCOA dues deduction was unlawful under section

536.150 because OA's decision was lawful under the Emergency Rule and under 1 C.S.R.

10-3.010 (2019); (8) finding OA's March 2020 decision denying MOCOA dues deduction

was arbitrary, capricious, and unreasonable under section 536.150 because the trial court's

factual findings do not satisfy the arbitrary and capricious standard; and (9) awarding

MOCOA injunctive relief because the requirements for injunctive relief were not met. We

affirm the judgment of the trial court.

Factual Background

MOCOA was established in 2000 as a non-profit corporation to promote the

interests and welfare of all corrections officers in Missouri by advocating for favorable

legislation, mitigating hazards of employment, improving working conditions, and raising

the social standing of its members. Only corrections officers employed by the DOC were

3 eligible for full membership, however the MOCOA Board of Directors was empowered to

pass a resolution allowing auxiliary membership to other persons who actively supported

the goals of MOCOA on account of family affiliation, work history, or other reasons.

Under Missouri law, certain groups may request OA to voluntarily have payments

from their members' paychecks automatically deducted and remitted toward the funding of

those groups. See section 33.103. Among the groups eligible to receive such membership

funding through automatic payroll deduction are labor unions and employee associations.

See id. At the time MOCOA was established, Missouri regulations defined each group: a

labor union was "an exclusive state employee bargaining representative established in

accordance with sections 105.500-105.530[;]" and an employee association was "an

organized group of state employees that has a written document, such as bylaws, which

govern its activity[.]" 1 C.S.R. 10-4.010(1)(B), (C) (1990). To receive payroll deduction,

employee associations, but not labor unions, were required to obtain a minimum of 100

state-employee-signed applications within ninety days of their request to OA for payroll

deduction. 1 C.S.R. 10-4.010(2)(F), (H) (1990).

In July 2000, MOCOA filed a request with OA that its members be permitted to

voluntarily deduct MOCOA dues from their paychecks. Although MOCOA was not a

labor union at the time, OA granted the request for payroll deduction because MOCOA

qualified as an employee association. Following the approval of payroll deductions for

MOCOA members, OA and DOC, which was responsible for payroll for corrections

officers, began deducting MOCOA dues owed by DOC employees pursuant to employee-

signed applications. The dues collected were remitted to MOCOA. New DOC employees

4 who signed authorization applications also had MOCOA dues deducted from their

paychecks.

In July 2004, Corrections Officers I and II voted to make MOCOA their exclusive

bargaining representative pursuant to section 105.525 (2000). Thus, MOCOA became

qualified as a labor union under the regulations. MOCOA and DOC entered into their first

labor agreement in February 2007 ("2007 Agreement"), which was set to expire in January

2011. Payroll deductions for MOCOA dues continued under the 2007 Agreement,

although the agreement did not specify whether dues were being deducted pursuant to

MOCOA's status as a labor union or employee association, or both. An internal memo

from OA in 2011 regarding payroll deductions for employee associations ("2011 memo")

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