AFSCME Council 31 v. State
2015 IL App (1st) 133454
| Ill. App. Ct. | 2015Background
- In 2013 the Illinois General Assembly enacted 5 ILCS 315/6.1, authorizing the Governor to designate up to 3,580 state positions (within 365 days) as excluded from collective bargaining if they meet specified criteria (titles, Rutan-exempt status, term appointments, or significant independent discretion).
- The Governor (via CMS) filed petitions to designate certain positions; the Illinois Labor Relations Board (ILRB) approved designations for five individual objectors, four based solely on the title "Senior Public Service Administrator" and one based on Rutan-exempt status.
- AFSCME (on behalf of the designated employees) challenged section 6.1 as unconstitutional, arguing: unlawful legislative delegation, equal protection/special legislation violations, procedural and substantive due process violations (including denial of evidentiary hearings), and unconstitutional impairment of existing collective bargaining agreements.
- The ILRB denied evidentiary hearings where the statute expressly authorized designation by title or specified criteria and rejected AFSCME's constitutional challenges; AFSCME appealed directly to this court.
- The appellate court reviewed legal questions de novo, upheld the ILRB decisions, and affirmed section 6.1 against all challenges.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Delegation of legislative power | Section 6.1 unlawfully delegates legislative authority to the Governor without adequate standards | Legislature provided specific categories, numerical limits, temporal limit, and ILRB review — so delegation is an execution of policy, not lawmaking | Upheld: delegation permissible; statute supplies adequate standards and limits; Governor's role is implementation not lawmaking |
| Procedural due process & evidentiary hearings | Short timelines and ILRB's refusal to hold evidentiary hearings denied meaningful notice and hearing | Statute provides procedural steps, short timelines were met, and statute permits designation by title or listed criteria without evidentiary hearings | Upheld: no facial due process violation; no entitlement to hearing where statute authorizes designation by title/criteria |
| Equal protection / special legislation | Section 6.1 arbitrarily treats some managerial employees differently and targets certain bargaining units | State has legitimate interest in governmental efficiency; distinctions are rationally related and reasonably tailored (numerical limits, specific categories, grandfathering) | Upheld under rational-basis review: classification rationally related to legitimate state interest; not arbitrary |
| Contract impairment (contracts clause) | Designations impair existing collective bargaining agreements by removing employees mid-contract | Designations change unit composition by statute; individual contractual benefits depend on continued statutory eligibility for unit membership; contracts contemplate legal changes | Upheld: no substantial impairment of bargained terms; statute prospectively alters eligibility and is valid exercise of police power |
Key Cases Cited
- Rutan v. Republican Party of Illinois, 497 U.S. 62 (1990) (regarding patronage and exemptions for certain public appointments)
- Mistretta v. United States, 488 U.S. 361 (1989) (permitting delegation to execute complex policies under broad directives)
- Mathews v. Diaz, 426 U.S. 67 (1976) (classification burdens and the inevitability of line-drawing in legislative classification)
- Heller v. Doe, 509 U.S. 312 (1993) (rational-basis review and burden on challenger to negative conceivable rationales)
- Roselle Police Pension Bd. v. Village of Roselle, 232 Ill. 2d 546 (2009) (statutory construction: give effect to legislative intent by plain meaning of text)