UE Local 893/IUP v. State of Iowa
928 N.W.2d 51
| Iowa | 2019Background
- UE Local 893 (union) and the State negotiated successor collective bargaining agreements; State submitted an initial offer on Dec. 20, 2016 reserving the right to revise.
- UE’s bargaining committee voted to accept the State’s Dec. 20 offer (Feb. 10, 2017) and UE membership ratified it (Feb. 14, 2017); the State stipulated it had not withdrawn the Dec. 20 offer before ratification but refused to acknowledge an enforceable contract.
- UE filed a prohibited-practice complaint with PERB and filed a district-court petition under Iowa Code § 20.17(5) to enforce the agreement; PERB stayed its own proceedings pending court resolution.
- The State moved to dismiss or stay the district action, arguing (a) Iowa Admin. Code r. 621—6.5(3) required the employer to vote to accept within a specified period (so no contract was formed without a State vote), and (b) PERB had primary jurisdiction and UE had not exhausted administrative remedies.
- The district court denied the motion to dismiss, declined to defer to PERB, and granted summary judgment to UE applying the Pepsi-Cola standard (an offer remains on the table unless withdrawn or circumstances reasonably indicate withdrawal).
- The Iowa Supreme Court affirmed: it held the State waived its challenge under rule 621—6.5(3) by failing to preserve the issue, rejected primary-jurisdiction and exhaustion defenses, and held an enforceable collective bargaining agreement was formed upon union acceptance and ratification.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Preservation of challenge to Iowa Admin. Code r. 621—6.5(3) | State raised the rule in preanswer motion to dismiss, so issue preserved for appeal | The State contends the rule voided formation absent employer vote and may be raised anytime as jurisdictional | Court: State waived the challenge by not pressing the rule in summary-judgment proceedings and not seeking a ruling after the district court reserved the issue; merits of the rule not reached |
| Subject-matter jurisdiction under § 20.17(5) | State: no enforceable contract existed (per rule), so court lacks jurisdiction to "enforce" | UE: § 20.17(5) grants district courts power to enforce agreements and to adjudicate contract validity as part of the enforcement action | Court: statute confers jurisdiction to adjudicate contract existence and enforce terms; defenses to formation are merits issues, not jurisdictional bars |
| Primary jurisdiction / exhaustion of administrative remedies | State: PERB has expertise and pending prohibited-practice complaints; court should stay or defer | UE: PERB lacks adequate remedies for contract enforcement; district court may decide enforcement | Court: primary jurisdiction and exhaustion not required here; PERB’s remedial powers are limited and district courts have concurrent jurisdiction to enforce contracts under § 20.17(5) |
| Contract formation / enforceability (Pepsi-Cola standard) | UE: ordinary contract principles and Pepsi-Cola apply; State’s offer remained on table; union acceptance + ratification formed enforceable agreement | State: UE’s conduct amounted to rejection/counteroffer; offer was contingent on legislative action and thus withdrawn/ineffective | Court: Adopted Pepsi-Cola standard; State stipulated it did not withdraw the offer; circumstances did not show a reasonable belief of withdrawal; summary judgment for UE affirmed |
Key Cases Cited
- Pepsi-Cola Bottling Co. of Mason City v. NLRB, 659 F.2d 87 (8th Cir. 1981) (adopted rule that a bargaining offer remains on table unless explicitly withdrawn or circumstances show reasonable belief of withdrawal)
- Meier v. Senecaut, 641 N.W.2d 532 (Iowa 2002) (preservation-of-error principles; issues must be raised and ruled on by trial court to preserve appellate review)
- Textron Lycoming Reciprocating Engine Div., Avco Corp. v. UAW, 523 U.S. 653 (1998) (interpretation that suits under §301 are for enforcement of labor contracts and may include adjudication of contract validity)
- ABF Freight Sys., Inc. v. Int’l Bhd. of Teamsters, 645 F.3d 954 (8th Cir. 2011) (federal courts have jurisdiction over breach-of-CBA actions even where conduct might constitute an unfair labor practice)
- United Steelworkers of Am. v. Warrior & Gulf Navigation Co., 363 U.S. 574 (1960) (framework recognizing collective bargaining’s distinct contract principles and duty to bargain in good faith)