Michigan Education Ass'n v. Secretary of State
489 Mich. 194
Mich.2010Background
- MEA is a voluntary labor organization representing about 136,000 public school employees; MEA-PAC is its separate segregated political fund funded mainly by member payroll deductions.
- Some collective bargaining agreements require the school district to administer a payroll-deduction plan directing MEA members’ contributions to the MEA-PAC; MEA proposed to reimburse all admin costs.
- Secretary of State ruled that absent statutory authority, the district may not expend public resources to administer the payroll-deduction plan for MEA-PAC.
- Court of Appeals held that § 57 MCFA prohibits use of public resources to make a contribution or expenditure, regardless of reimbursement, and affirmed the trial court’s ruling.
- This Court granted rehearing; majority now holds the district’s administration of the plan violates § 57 by constituting both a contribution and an expenditure; MEA’s reimbursement does not cure the violation.
- Dissent argues the district’s actions are excluded from the definitions of expenditure and contribution, or are permissible under other statutory provisions, and would uphold the trial court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether payroll deductions administered by a public school district for MEA-PAC are a prohibited contribution or expenditure | MEA argues administration uses public resources to create/contribute to MEA-PAC. | District contends administration is not a contribution or expenditure under the MCFA definitions. | Yes; both a contribution and an expenditure. |
| Whether prepayment/reimbursement by MEA cures § 57 violation | N/A (MEA posits reimbursement could offset costs). | Reimbursement does not cure a prohibited use of public resources. | No; reimbursement does not cure the violation. |
| Whether the § 6(2)(c) exclusion permits a public body to treat payroll deduction admin as exempt | N/A (majority adopts exclusion for separate segregated funds). | Public bodies are not authorized to establish a separate segregated fund, so exclusion does not apply. | No; § 6(2)(c) excludes only entities authorized to create/ administer funds, not public bodies. |
| Whether MCFA authorizes a school district to administer payroll deductions under its collective-bargaining authority | N/A (dissent argues authority is not granted to administer such deductions). | District has authority to enter collective-bargaining agreements and administer payroll deductions for such purposes. | No; authority to administer such payroll deductions for political contributions is not granted. |
Key Cases Cited
- Mich Ed Ass’n v Secretary of State, 488 Mich 18 (Mich. 2010) (central governing MCFA interpretation on § 57 and payroll deduction plan)
- Mich Ed Ass’n v Secretary of State, 280 Mich App 477 (Mich. Ct. App. 2008) (Court of Appeals held reimbursement does not negate expenditures)
- Frankenmuth Mut Ins Co v Marlette Homes, Inc., 456 Mich 511 (Mich. 1998) (statutory interpretation and intent principles)
- Sun Valley Foods Co v Ward, 460 Mich 230 (Mich. 1999) (statutory interpretation; harmony of enactment)
- Robinson v Detroit, 462 Mich 439 (Mich. 2000) (factors for overrule of prior precedent (Robinson framework))
- Petersen v Magna Corp, 484 Mich 300 (Mich. 2009) (stare decisis and overrule considerations)
- United States Fidelity & Guaranty Co v Mich Catastrophic Claims Ass’n (On Rehearing), 484 Mich 1 (Mich. 2009) (on rehearing; discussion of retroactive effect and precedent)