Teamsters Local 214 v. Pauline Beutler, 330854

Background

Charging party (a bus driver) signed a union membership application and a dues-deduction authorization in 2011 that described the authorization as "irrevocable for the term of the applicable contract or for one year" and automatically renewing unless revoked by written notice given 60–75 days before a renewal date.
The collective bargaining agreement in effect expired June 30, 2013; a new agreement effective July 1, 2013, took into account recent "right-to-work" legislation (2012 PA 349 and 2012 PA 53) and contained no union-security or employer check-off for dues.
In September 2013 the charging party sent a letter to the union president asserting her statutory right to refrain from union support under the new law and seeking to stop financial support immediately.
The union replied that the dues-deduction authorization was an independent contract that remained binding and barred immediate revocation outside the contract’s specified revocation window.
The Michigan Employment Relations Commission (MERC) found the resignation letter effective upon receipt but held the dues obligation remained until the next permitted revocation window under the dues-deduction agreement; the Court of Appeals affirmed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the dues-deduction authorization constituted a clear, explicit, and unmistakable waiver of the statutory right to cease financial support at will	Beutler: Right-to-work statutory right allows immediate discontinuation; union bylaws/contract cannot override statutory right	Teamsters: The signed dues authorization is an independent contract that irrevocably assigns wages for the contract term and automatically renews; it limits revocation to specified windows	Court: The authorization was a clear, explicit, and unmistakable contractual waiver of immediate discontinuation; dues obligation continued until the contract-specified revocation window
Whether Act 53/Act 349 voided or otherwise invalidated preexisting lawful dues-payment obligations	Beutler: The statutes create a right to stop financial support immediately	Teamsters: Acts altered employer check-off practice but did not eliminate lawful contractual obligations of employees to pay dues	Court: Act 53 changed employer check-off rights but did not alter lawful employee dues obligations; contract remains enforceable
Whether the renewed collective-bargaining agreement altered the dues authorization without additional assent	Beutler: Renewal shouldn’t bind her beyond statutory rights	Teamsters: The dues authorization automatically renewed with the new CBA per its terms, creating a new enforceable agreement	Court: The authorization automatically renewed when the new CBA took effect; failure to timely revoke constituted waiver of immediate discontinuation
Whether MERC’s factual findings are supported by substantial evidence	Beutler: MERC misapplied Saginaw Ed Ass’n and mischaracterized the agreement	Teamsters: MERC’s findings correctly distinguished this contract from the agreements in other cases and are supported by the record	Court: MERC’s findings are supported by competent, material, substantial evidence and its legal conclusions were affirmed

Key Cases Cited

Grandville Mun. Exec. Ass’n v. City of Grandville, 453 Mich. 428; 553 N.W.2d 917 (Mich. 1996) (administrative findings of fact are conclusive if supported by substantial evidence)
In re Complaint of Rovas Against SBC Michigan, 482 Mich. 90; 754 N.W.2d 259 (Mich. 2008) (court gives respectful consideration to agency statutory interpretations but is not bound if inconsistent with plain language)
Rory v. Continental Ins. Co., 473 Mich. 457; 703 N.W.2d 23 (Mich. 2005) (contractual freedom and enforcement of voluntarily made agreements)
Terrien v. Zwit, 467 Mich. 56; 648 N.W.2d 602 (Mich. 2002) (contract principles affirming validity of voluntary agreements)
21st Century Premier Ins. Co. v. Zufelt, 315 Mich. App. 437; 889 N.W.2d 759 (Mich. Ct. App. 2016) (automatic renewal can create a new, distinct contract)