Massachusetts General Laws

Mass. Gen. Laws ch. 150E, § 9A (2026)

Strikes prohibited; investigation; enforcement proceedings

✓ current as of July 2026

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Section 9A. (a) No public employee or employee organization shall engage in a strike, and no public employee or employee organization shall induce, encourage or condone any strike, work stoppage, slowdown or withholding of services by such public employees.

(b) Whenever a strike occurs or is about to occur, the employer shall petition the commission to make an investigation. If, after investigation, the commission determines that any provision of paragraph (a) of this section has been or is about to be violated, it shall immediately set requirements that must be complied with, including, but not limited to, instituting appropriate proceedings in the superior court for the county wherein such violation has occurred or is about to occur for enforcement of such requirements.

Notes of Decisions

Cited in 23 cases, 1977–2015 · leading case: Labor Relations Comm'n v. Fall River Educators Ass'n, 416 N.E.2d 1340 (Mass. 1981).

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Labor Relations Comm'n v. Fall River Educators Ass'n, 416 N.E.2d 1340 (Mass. 1981). · cites it 4× “Earlier, on September 6, 1978, anticipating that a strike was about to occur, the Fall River school committee petitioned the Labor Relations Commission (Commission) to make an investigation pursuant to G. L. c. 150E, § 9A (b). A hearing on the petition was *467 scheduled, by…”

Quincy City Hosp. v. Labor Relations Comm'n, 511 N.E.2d 582 (Mass. 1987). · cites it 2× “715 , 717 (1986) (petition for investigation under G.L.c. 150E, § 9A [1984 ed.]). Because the hospital exhausted its administrative remedies, review of the prehearing dismissal would not violate the primary concern of the "final order" requirement allowing "a fair opportunity…”

Meagher v. Andover Sch. Comm., 94 F. Supp. 3d 21 (D. Mass. 2015). · cites it 2× “The ASC denied the charges, and asserted that Meagher’s email had advocated an unlawful withholding of essential services, in violation of Mass. Gen. Laws ch. 150E, § 9A. (Id.). While the DLR matter remained pending, Meagher applied for another teaching position.”

Util. Workers of Am. v. Labor Relations Comm'n, 451 N.E.2d 124 (Mass. 1983). · cites it 4× “The union does not dispute that this work stoppage violated G. L. c. 150E, § 9A (a). On the morning of April 29, 1981, Edward Courchene, the general manager of the waste disposal department, called Charles M.”

Allen v. Sch. Comm. of Boston, 487 N.E.2d 529 (Mass. 1986). · cites it 7× “” G. L. c. 150E, § 9A (a) (1984 ed.). We note that G.”

Boston Hous. Auth. v. Nat'l Conf. of Firemen & Oilers, Local 3, 935 N.E.2d 1260 (Mass. 2010). “VTH of the CBA between the BHA and Local 3, the BHA’s employees — like all other public employees, see G. L. c. 150E, § 9A (a) — are not permitted to strike, arbitration has been contractually mandated for resolution of grievances under all their CBAs, and there is a strong…”

Int'l Org. of Masters, Mates & Pilots, Atl. & Gulf Mar. Region v. Woods Hole, Martha's Vineyard & Nantucket S.S. Auth., 467 N.E.2d 1331 (Mass. 1984). “See G. L. c. 150E, § 9A (b), inserted by St. 1973, c.”

Lenox Educ. Ass'n v. LABOR RELATIONS COMM., 471 N.E.2d 81 (Mass. 1984). · cites it 3× “We also decide that a public employer may discipline, without the employer’s first petitioning the commission to make an investigation pursuant to G. L. c. 150E, § 9A (b), employees who are engaged in or who are about to engage in an unlawful strike.”

Boston Hous. Auth. v. Labor Relations Comm'n, 500 N.E.2d 802 (Mass. 1986). · cites it 6× “On November 18, 1985, the Boston Housing Authority (authority) filed with the Labor Relations Commission (commission) a petition for investigation of a strike, pursuant to G.L.c. 150E, § 9A. [2] The authority alleged that the *716 Massachusetts Laborers District Council, I/B/O…”

City of Somerville v. Commonwealth Emp. Relations Bd., 24 N.E.3d 552 (Mass. 2015). “, G. L. c. 150E, § 9A (a) (prohibiting public employees and their organizations from engaging in strikes).”

Labor Relations Comm'n v. Boston Teachers Union, 371 N.E.2d 761 (Mass. 1977). “*82 As a result of the action taken at the meeting, the committee filed a petition on September 12 with the Labor Relations Commission (commission) for a strike investigation under G. L. c. 150E, § 9A (b). Such an investigation was conducted.”

Boston Teachers Union, Local 66 v. Edgar, 787 F.2d 12 (1st Cir. 1986). · cites it 4× “The Boston Teachers Union, Local 66, AFT, AFD-CIO (the “Union”), brought an action against the Boston School Committee and the Commissioners of the Massachusetts Labor Relations Commission seeking a declaration that the provisions of Mass.Gen.Laws ch. 150E, § 9A (1984), which…”

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— Mass. Gen. Laws ch. 150E, § 9A(a) — 4 cases

Meagher v. Andover Sch. Comm., 94 F. Supp. 3d 21 (D. Mass. 2015). “The ASC denied the charges, and asserted that Meagher’s email had advocated an unlawful withholding of essential services, in violation of Mass. Gen. Laws ch. 150E, § 9A. (Id.). While the DLR matter remained pending, Meagher applied for another teaching position.”

Util. Workers of Am. v. Labor Relations Comm'n, 451 N.E.2d 124 (Mass. 1983). “The union does not dispute that this work stoppage violated G. L. c. 150E, § 9A (a). On the morning of April 29, 1981, Edward Courchene, the general manager of the waste disposal department, called Charles M.”

Boston Teachers Union, Local 66 v. Edgar, 787 F.2d 12 (1st Cir. 1986). “The Boston Teachers Union, Local 66, AFT, AFD-CIO (the “Union”), brought an action against the Boston School Committee and the Commissioners of the Massachusetts Labor Relations Commission seeking a declaration that the provisions of Mass.Gen.Laws ch. 150E, § 9A (1984), which…”

Roumeliotis v. Zenga, 2 Mass. Supp. 54 (Mass. Super. Ct. 1980).

— Mass. Gen. Laws ch. 150E, § 9A(b) — 2 cases

— Mass. Gen. Laws ch. 150E, § 9A(ú) — 1 case

Sch. Comm. of Boston v. Labor Relations Comm'n, 512 N.E.2d 1151 (Mass. App. Ct. 1987).

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