Massachusetts General Laws

Mass. Gen. Laws ch. 150E, § 10 (2026)

Prohibited practices

✓ current as of July 2026
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Section 10. (a) It shall be a prohibited practice for a public employer or its designated representative to:

(1) Interfere, restrain, or coerce any employee in the exercise of any right guaranteed under this chapter;

(2) Dominate, interfere, or assist in the formation, existence, or administration of any employee organization;

(3) Discriminate in regard to hiring, tenure, or any term or condition of employment to encourage or discourage membership in any employee organization;

(4) Discharge or otherwise discriminate against an employee because he has signed or filed an affidavit, petition, or complaint or given any information or testimony under this chapter, or because he has informed, joined, or chosen to be represented by an employee organization;

(5) Refuse to bargain collectively in good faith with the exclusive representative as required in section six;

(6) Refuse to participate in good faith in the mediation, fact-finding, and arbitration procedures set forth in sections eight and nine;

(b) It shall be a prohibited practice for an employee organization or its designated agent to:

(1) Interfere, restrain, or coerce any employer or employee in the exercise of any right guaranteed under this chapter;

(2) Refuse to bargain collectively in good faith with the public employer, if it is an exclusive representative, as required in section six;

(3) Refuse to participate in good faith in the mediation, fact finding and arbitration procedures set forth in sections eight and nine.

Notes of Decisions
Cited in 119 cases (10 in the last 5 years), 1977–2025 · leading case: City of Somerville v. Commonwealth Emp. Relations Bd., 24 N.E.3d 552 (Mass. 2015).
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City of Somerville v. Commonwealth Emp. Relations Bd., 24 N.E.3d 552 (Mass. 2015). · cites it 10× “At issue in this case is whether the city of Somerville (city) and the school committee of Somerville (school committee) violated G. L. c. 150E, § 10 (a) (5), and, derivatively, G.”
Sch. Comm. of Newton v. Labor Relations Comm., 447 N.E.2d 1201 (Mass. 1983). · cites it 6× “These appeals concern decisions of the Labor Relations Commission (commission) finding that the *559 School Committee of Newton (school committee) violated G. L. c. 150E, § 10 (a) (1) and (5), in unilaterally deciding to lay off certain school custodians, members of the…”
Branch v. Commonwealth Emp. Relations Bd., 120 N.E.3d 1163 (Mass. 2019). · cites it 4× “6 The employees alleged that the requirement that they pay agency fees constituted a prohibited practice under G. L. c. 150E, §§ 10 ( a ) (1), (3), ( b ) (1), and 12, because "compulsory union fees .”
S. Worcester Cty. Reg. Sch. Dist. v. Labor Rel. Comm'n, 436 N.E.2d 380 (Mass. 1982). · cites it 6× “We granted the Labor Relations Commission's (commission) application for further appellate review to set out the legal standard and burden of proof which should govern unlawful discharge cases arising under G.L.c. 150E, § 10 ( a ) (1) & (3). [1] We also consider the remedial…”
City of Boston v. Commonwealth Emp. Relations Bd., 902 N.E.2d 410 (Mass. 2009). · cites it 6× “(2000) (Act), for the purpose of computing future overtime compensation owed to city police officers constituted a breach of the city’s duty to bargain with the union in good faith under G. L. c. 150E, § 10 (a). See 29 U.S.C. § 207 (k) (2000).”
Commonwealth v. Commonwealth Emp. Relations Bd. & Another., 101 Mass. App. Ct. 616 (Mass. App. Ct. 2022). · cites it 5× “Substantial evidence supported the conclusion of the Commonwealth Employment Relations Board that the Commonwealth engaged in a unilateral change in terms and conditions of employment in violation of G. L. c. 150E, § 10 (a) (1) and (5), when MassHealth managers surreptitiously…”
Comm'r of Admin. & Fin. v. Commonwealth Emp. Relations Bd., 74 N.E.3d 610 (Mass. 2017). · cites it 3× “150E, §7 (b), and also that the letter constituted a failure to bargain in good faith, in violation of G. L. c. 150E, § 10 (a) (5). In January, 2014, a hearing officer with the division agreed with the unions and found that the Commonwealth had violated its § 7 (b) duty and had…”
Town of North Attleboro v. Labor Relations Comm'n, 779 N.E.2d 654 (Mass. App. Ct. 2002). · cites it 6× “On August 4, 1995, the North Attleboro firefighters, Local 1992, International Association of Firefighters (union) filed a charge with the Labor Relations Commission (commission) alleging that the town of North Attleboro (town) had engaged in prohibited practices in violation of…”
S. Worcester Cnty. Reg'l Vocational Sch. Dist. v. Labor Relations Comm'n, 436 N.E.2d 380 (Mass. 1982). · cites it 5× “We granted the Labor Relations Commission’s (commission) application for further appellate review to set out the legal standard and burden of proof which should govern unlawful discharge cases arising under G. L. c. 150E, § 10 (a) (1) & (3). 1 We also consider the remedial *415…”
City of Worcester v. Labor Relations Comm'n, 438 Mass. 177 (Mass. 2002). · cites it 2× “150E, § 6, and therefore, the city’s failure to bargain over that decision was not a violation of G. L. c. 150E, § 10 (a) (5). However, the commission held that there remained an obligation to bargain over the impact of such management decisions, and the special order had an…”
Boston Hous. Auth. v. Nat'l Conf. of Firemen & Oilers, Local 3, 935 N.E.2d 1260 (Mass. 2010). · cites it 2× “Further, we do not address whether the BHA committed any unfair labor practices when it laid off the firemen on April 30, 2006, and we do not speculate about Local 3’s rights with respect to any subsequent proceedings under G. L. c. 150E, § 10, pertaining to prohibited practices.”
Anderson v. Commonwealth Emp. Relations Bd., 899 N.E.2d 901 (Mass. App. Ct. 2009). · cites it 4× “* 5 The board dismissed the plaintiffs’ charge without a hearing, citing lack of probable cause to believe that the union violated G. L. c. 150E, § 10(A)(1). 6 The board concluded that the sick leave provision did not, without more, warrant the inference that the union had…”
Show all 119 citing cases →
— Mass. Gen. Laws ch. 150E, § 10(6) — 1 case
Switzer v. Labor Relations Comm'n, 633 N.E.2d 1056 (Mass. App. Ct. 1994).
— Mass. Gen. Laws ch. 150E, § 10(6)(1) — 2 cases
Goncalves v. Labor Relations Comm'n, 682 N.E.2d 914 (Mass. App. Ct. 1997).
United Steelworkers of Am. v. Commonwealth Emp. Relations Bd., 909 N.E.2d 1177 (Mass. App. Ct. 2009).
— Mass. Gen. Laws ch. 150E, § 10(A)(1) — 1 case
Anderson v. Commonwealth Emp. Relations Bd., 899 N.E.2d 901 (Mass. App. Ct. 2009). “* 5 The board dismissed the plaintiffs’ charge without a hearing, citing lack of probable cause to believe that the union violated G. L. c. 150E, § 10(A)(1). 6 The board concluded that the sick leave provision did not, without more, warrant the inference that the union had…”
— Mass. Gen. Laws ch. 150E, § 10(a) — 8 cases
Boston Police Superior Officers Fed'n v. Labor Relations Comm'n, 575 N.E.2d 1131 (Mass. 1991).
Nat'l Ass'n of Gov't Employees, Local R1-162 v. Labor Relations Comm'n, 460 N.E.2d 619 (Mass. App. Ct. 1984).
Pattison v. Labor Relations Comm'n, 565 N.E.2d 801 (Mass. App. Ct. 1991).
Town of Burlington v. Labor Relations Comm'n, 459 N.E.2d 125 (Mass. App. Ct. 1984).
Bd. of Selectmen v. Labor Relations Comm'n, 453 N.E.2d 466 (Mass. App. Ct. 1983).
— Mass. Gen. Laws ch. 150E, § 10(a)(1) — 27 cases
Sheriff v. Labor Relations Comm'n, 805 N.E.2d 46 (Mass. App. Ct. 2004).
City of Lynn v. Labor Relations Comm'n, 681 N.E.2d 1234 (Mass. App. Ct. 1997).
Commonwealth v. Labor Relations Comm'n, 533 N.E.2d 1326 (Mass. 1989).
Town of North Attleboro v. Labor Relations Comm'n, 779 N.E.2d 654 (Mass. App. Ct. 2002). “On August 4, 1995, the North Attleboro firefighters, Local 1992, International Association of Firefighters (union) filed a charge with the Labor Relations Commission (commission) alleging that the town of North Attleboro (town) had engaged in prohibited practices in violation of…”
Util. Workers of Am. v. Labor Relations Comm'n, 451 N.E.2d 124 (Mass. 1983).
— Mass. Gen. Laws ch. 150E, § 10(a)(2) — 1 case
Town of North Attleboro v. Labor Relations Comm'n, 779 N.E.2d 654 (Mass. App. Ct. 2002). “On August 4, 1995, the North Attleboro firefighters, Local 1992, International Association of Firefighters (union) filed a charge with the Labor Relations Commission (commission) alleging that the town of North Attleboro (town) had engaged in prohibited practices in violation of…”
— Mass. Gen. Laws ch. 150E, § 10(a)(3) — 3 cases
Graupner v. Town of Brookfield, 450 F. Supp. 2d 119 (D. Mass. 2006).
Ash v. Police Comm'r, 418 N.E.2d 622 (Mass. App. Ct. 1981).
Massachusetts Bd. of Reg'l Cmty. Colleges v. Labor Relations Comm'n, 388 N.E.2d 1185 (Mass. 1979).
— Mass. Gen. Laws ch. 150E, § 10(a)(5) — 17 cases
Bd. of Selectmen of Marion v. Labor Relations Comm'n, 388 N.E.2d 302 (Mass. App. Ct. 1979).
Town of North Attleboro v. Labor Relations Comm'n, 779 N.E.2d 654 (Mass. App. Ct. 2002). “On August 4, 1995, the North Attleboro firefighters, Local 1992, International Association of Firefighters (union) filed a charge with the Labor Relations Commission (commission) alleging that the town of North Attleboro (town) had engaged in prohibited practices in violation of…”
Chief Just. for Admin. & Mgmt. of the Trial Court v. Commonwealth Emp. Relations Bd., 946 N.E.2d 704 (Mass. App. Ct. 2011).
Pattison v. Labor Relations Comm'n, 565 N.E.2d 801 (Mass. App. Ct. 1991).
City of Boston v. Labor Relations Comm'n, 718 N.E.2d 875 (Mass. App. Ct. 1999).
— Mass. Gen. Laws ch. 150E, § 10(a)(6) — 1 case
West Bridgewater Police Ass'n v. Labor Relations Comm'n, 468 N.E.2d 659 (Mass. App. Ct. 1984).
— Mass. Gen. Laws ch. 150E, § 10(b) — 1 case
Boston Police Patrolmen's Ass'n v. Labor Relations Comm'n, 451 N.E.2d 731 (Mass. App. Ct. 1983).
— Mass. Gen. Laws ch. 150E, § 10(b)(1) — 5 cases
Anderson v. Commonwealth Emp. Relations Bd., 899 N.E.2d 901 (Mass. App. Ct. 2009). “* 5 The board dismissed the plaintiffs’ charge without a hearing, citing lack of probable cause to believe that the union violated G. L. c. 150E, § 10(A)(1). 6 The board concluded that the sick leave provision did not, without more, warrant the inference that the union had…”
Pattison v. Labor Relations Comm'n, 565 N.E.2d 801 (Mass. App. Ct. 1991).
United Steelworkers of Am. v. Commonwealth Emp. Relations Bd., 909 N.E.2d 1177 (Mass. App. Ct. 2009).
S. Worcester Cnty. Reg'l Vocational Sch. Dist. v. Labor Relations Comm'n, 389 N.E.2d 389 (Mass. 1979).
Boston Police Patrolmen's Ass'n v. Labor Relations Comm'n, 451 N.E.2d 731 (Mass. App. Ct. 1983).
— Mass. Gen. Laws ch. 150E, § 10(c) — 1 case
S. Worcester Cnty. Reg'l Vocational Sch. Dist. v. Labor Relations Comm'n, 422 N.E.2d 791 (Mass. App. Ct. 1981).
— Mass. Gen. Laws ch. 150E, § 10(c)(1) — 1 case
S. Worcester Cnty. Reg'l Vocational Sch. Dist. v. Labor Relations Comm'n, 422 N.E.2d 791 (Mass. App. Ct. 1981).
— Mass. Gen. Laws ch. 150E, § 10(c)(3) — 1 case
Town of Burlington v. Labor Relations Comm'n, 459 N.E.2d 125 (Mass. App. Ct. 1984).
— Mass. Gen. Laws ch. 150E, § 10(c)(5) — 1 case
Int'l Bhd. of Police Officers v. Labor Relations Comm'n, 415 N.E.2d 863 (Mass. App. Ct. 1981).
— Mass. Gen. Laws ch. 150E, § 10(g)(5) — 1 case
Springfield Hous. Auth. v. Labor Relations Comm'n, 454 N.E.2d 507 (Mass. App. Ct. 1983).
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