Michigan Education Association v. Secretary of State
488 Mich. 18
Mich.2010Background
- MEA represents public school employees; MEA-PAC is a separate segregated fund under MCFA.
- Gull Lake Schools’ CBAs require the district to administer payroll deductions to MEA-PAC, with MEA prepaid for administration costs.
- Secretary of State ruled payroll deductions to MEA-PAC violated §57 (169.257) of MCFA, prohibiting public resources for political contributions/expenditures.
- Trial court voided the ruling; Court of Appeals reversed, holding administration was an expenditure prohibited by §57.
- Michigan Supreme Court granted review to decide if public-body payroll deductions to MEA-PAC are allowed under MCFA.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does § 57 prohibit a public body from administering payroll deductions to MEA-PAC? | MEA argues no prohibition because administration falls outside expenditure/contribution. | Secretary of State and Respondent contend administration uses public resources for political purposes in violation of § 57. | Yes; the court held administration is permissible (reversed Court of Appeals). |
| Is the payroll-deduction administration an ‘expenditure’ under MCFA? | Administration falls within general expenditure, applied to benefit MEA-PAC. | Administration is excluded as an expenditure because it is for establishment/administration of contributions to a segregated fund. | Not an expenditure due to statutory exclusion. |
| Is the payroll-deduction administration a ‘contribution’ under MCFA? | Costs transfer to MEA-PAC could be a contribution. | Prepaid/advance costs negate net transfer of value, so no contribution. | Not a contribution where costs are prepaid; no net transfer of value. |
| Does the plan constitute ‘volunteer personal services’ prohibited by § 57? | Administration could be volunteer services by public employees. | MEA prepayment means no volunteer services by public employees. | Not volunteer services under § 57. |
Key Cases Cited
- Mich Ed Ass’n v Secretary of State, 280 Mich App 477 (2008) ( Court of Appeals decision addressing MCFA §57 and expenditures)
- Mich Ed Ass’n v Secretary of State, 483 Mich 1001 (2009) (Supreme Court order directing briefing; discusses statutory interpretation)
- Mich Ed Ass’n v Secretary of State, 486 Mich 952 (2010) (Court decision granting leave; discusses scope of MCFA post-Citizens United)
- Tryc v Michigan Veterans’ Facility, 451 Mich 129 (1996) (statutory interpretation principles and public funds; ABSENT)
- Sun Valley Foods Co v Ward, 460 Mich 230 (1999) (absurd results doctrine in statutory interpretation)