Bedford Public Schools v. Bedford Education Ass'n
305 Mich. App. 558
| Mich. Ct. App. | 2014Background
- BEA charged Bedford Public Schools with PERA violations and failing to grant lane-change wage increases after expiration of the CBA.
- Expired CBA was in effect until June 30, 2010; negotiations for a new CBA were ongoing but unsuccessful by May 2010.
- 2011 PA 54 added MCL 423.215b, restricting wages and benefits after expiration until a successor CBA is in place.
- MCL 423.215b(l) expressly limits levels and amounts of wages and benefits to those in effect on expiration; BEA argued this excludes lane changes, which are based on education level.
- MERC concluded that the statute prohibits lane changes in the absence of a new CBA; BEA appealed, arguing a narrower scope limited to step increases.
- The Michigan Court of Appeals conducted de novo statutory interpretation, held the statute unambiguously prohibits all wage increases, including lane changes, absent a new CBA, and applied prospectively.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does MCL 423.215b(l) bar wage increases, including lane changes, when no successor CBA exists? | BEA/BEA argued lane changes are not within l's scope. | Board argued lane changes are prohibited by l as part of overall wage increases. | Unambiguous prohibition on all wage increases absent a new CBA. |
| Did BEA have a vested right to lane changes prior to 2011? | BEA contends a vested right existed to lane changes. | Board contends no vested right survived expiration; statute may extinguish. | No vested right; rights subject to bargaining do not survive expiration; statute applied prospectively. |
| Is MCL 423.215b unconstitutional as applied to BEA? | BEA claims retroactive deprivation of vested rights. | Legislature validly extinguished unvested or post-June 8, 2011 expectations. | Constitutionality upheld; statute applied prospectively and not retroactive. |
Key Cases Cited
- Gen Motors Corp v Dep’t of Treasury, 290 Mich App 355 (Mich. Ct. App. 2010) (vested rights concept and governing standards)
- Mt Pleasant Sch, 302 Mich App 600 (Mich. Ct. App. 2013) (statutory interpretation and ambiguity standards)
- Ottawa Co v Jaklinski, 423 Mich 1 (Mich. 1985) (scope of bargaining rights and nonvested expectations)
- Amalgamated Transit Union v Southeastern Mich Transp Auth, 437 Mich 441 (Mich. 1991) (deference to agency interpretations under PERA)
- Jackson Community College Classified & Technical Ass’n v Jackson Community College, 187 Mich App 708 (Mich. App. 1991) (step increases and contract terms under expired CBAs)