Mich. Comp. Laws » Michigan Compiled Laws / Chapter 37 / Act 453 of 1976
Michigan Compiled Laws

Mich. Comp. Laws § 37.2204 (2026)

Labor organization; prohibited practices generally.

✓ current as of July 2026
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ELLIOTT-LARSEN CIVIL RIGHTS ACT


Act 453 of 1976


37.2204 Labor organization; prohibited practices generally.

Sec. 204.

    A labor organization shall not do any of the following:

    (a) Exclude or expel from membership, or otherwise discriminate against, a member or applicant for membership because of religion, race, color, national origin, age, sex, sexual orientation, gender identity or expression, height, weight, or marital status.

    (b) Limit, segregate, or classify membership or applicants for membership, or classify or fail or refuse to refer for employment an individual in a way that would deprive or tend to deprive that individual of an employment opportunity, or that would limit an employment opportunity, or that would adversely affect wages, hours, or employment conditions, or otherwise adversely affect the status of an employee or an applicant for employment, because of religion, race, color, national origin, age, sex, sexual orientation, gender identity or expression, height, weight, or marital status.

    (c) Cause or attempt to cause an employer to violate this article.

    (d) Fail to fairly and adequately represent a member in a grievance process because of religion, race, color, national origin, age, sex, sexual orientation, gender identity or expression, height, weight, or marital status.

    

    

History: 1976, Act 453, Eff. Mar. 31, 1977 ;-- Am. 2023, Act 6, Eff. Feb. 13, 2024

Notes of Decisions
Cited in 14 cases (2 in the last 5 years), 1985–2023 · leading case: Wrobbel v. Int'l Bhd. of Elec. Workers, Local 17, 638 F. Supp. 2d 780 (E.D. Mich. 2009).
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Wrobbel v. Int'l Bhd. of Elec. Workers, Local 17, 638 F. Supp. 2d 780 (E.D. Mich. 2009). · cites it 5× “It is the provisions of§ 37.2204 that apply to labor unions. Both the state and federal statute make it unlawful for a labor organization to "fail or refuse to refer for employment any individual .”
Kassab v. Michigan Basic Prop. Ins., 491 N.W.2d 545 (Mich. 1992). · cites it 2× “548[202]) from discharging, and a labor organization (MCL 37.2204; MSA 3.548[204]) or educational institution (MCL 37.”
Jones v. Cassens Transp., 617 F. Supp. 869 (E.D. Mich. 1985). · cites it 5× “§ 37.2204, as follows: Sec. 204. A labor organization shall not: (a) Exclude or expel from membership, or otherwise discriminate against, a member or applicant for membership because of religion, race, color, national origin, age, sex, height, weight, or marital status.”
Bondurant v. Air Line Pilots Ass'n, Int'l, 679 F.3d 386 (6th Cir. 2012). “§ 623 (c)(1), and Michigan’s Elliot-Larsen Civil Rights Law, Mich. Comp. Laws § 37.2204 (a) (1977). II.”
Frances Jones Beverly Harder Eleanor Murray Linda Wickel & Mary Ruane v. Cassens Transp. Truck Drivers Local 299, 982 F.2d 983 (6th Cir. 1993). “2204(d), which prohibits labor organizations from: “(d) Fail[ing] to fairly and adequately represent a member in a grievance process because of religion, race, color, national origin, age, sex, height, weight, or marital status.” The language of the collective bargaining…”
Bondurant v. Air Line Pilots Ass'n, 718 F. Supp. 2d 836 (E.D. Mich. 2010). · cites it 2× “Similarly, under EL-CRA, a labor organization shall not segregate or classify its membership because of age in a way that would adversely affect the employees benefits or conditions of employment.”
Jones v. Pepsi Cola Bottling Co., Inc., 822 F. Supp. 396 (E.D. Mich. 1993). · cites it 3× “§ 37.2204. Count XII claims that Pepsi violated the Employee Retirement Income Security Act of 1974, 29 U.”
Jones v. Truck Drivers Local Union No. 299, 838 F.2d 856 (6th Cir. 1988). · cites it 2× “Section 204 of the EIliott-Larsen Act, Mich. Comp.Laws Ann. § 37.2204, provides: 37.”
Bredesen v. Detroit Fed'n of Musicians, Local No. 5, 165 F. Supp. 2d 647 (E.D. Mich. 2001). “§ 37.2204, which provides: Sec. 204. A labor organization shall not: (a) Exclude or expel from membership, or otherwise discriminate against a member or applicant for membership because of religion, race, color, national origin, age, sex, height, weight, or marital status.”
Brown v. United Auto., Aerospace & Agric. Implement Workers, Local 892, 682 F. Supp. 901 (E.D. Mich. 1987). “§ 37.2204(d) and M.C.L.A. § 37.-2202(l)(a).”
Tisdale v. United Ass'n of Journeymen & Apprentices of the Plumbing & Pipefitting Indus. of the United States & Canada, Local 704, 25 F.3d 1308 (6th Cir. 1994). “Mich. Comp. Laws Ann. §§ 37.2204 (West 1985).”
Safiedine v. City of Ferndale, 753 N.W.2d 260 (Mich. Ct. App. 2008). “2203; MCL 37.2204. Article 3 of the CRA, Public *484 Accommodations and Services, prohibits the denial of “the full and equal enjoyment of the goods, services, facilities, privileges, advantages, or accommodations of a place of public accommodation or public service because of…”
Show all 14 citing cases →
— Mich. Comp. Laws § 37.2204(a) — 3 cases
Jones v. Cassens Transp., 617 F. Supp. 869 (E.D. Mich. 1985). “§ 37.2204, as follows: Sec. 204. A labor organization shall not: (a) Exclude or expel from membership, or otherwise discriminate against, a member or applicant for membership because of religion, race, color, national origin, age, sex, height, weight, or marital status.”
Jones v. Truck Drivers Local Union No. 299, 838 F.2d 856 (6th Cir. 1988). “Section 204 of the EIliott-Larsen Act, Mich. Comp.Laws Ann. § 37.2204, provides: 37.”
Scott Vandercook v. State Police (Mich. Ct. App. 2023).
— Mich. Comp. Laws § 37.2204(b) — 2 cases
Wrobbel v. Int'l Bhd. of Elec. Workers, Local 17, 638 F. Supp. 2d 780 (E.D. Mich. 2009). “It is the provisions of§ 37.2204 that apply to labor unions. Both the state and federal statute make it unlawful for a labor organization to "fail or refuse to refer for employment any individual .”
Jones v. Pepsi Cola Bottling Co., Inc., 822 F. Supp. 396 (E.D. Mich. 1993). “§ 37.2204. Count XII claims that Pepsi violated the Employee Retirement Income Security Act of 1974, 29 U.”
— Mich. Comp. Laws § 37.2204(c) — 1 case
Jones v. Cassens Transp., 617 F. Supp. 869 (E.D. Mich. 1985). “§ 37.2204, as follows: Sec. 204. A labor organization shall not: (a) Exclude or expel from membership, or otherwise discriminate against, a member or applicant for membership because of religion, race, color, national origin, age, sex, height, weight, or marital status.”
— Mich. Comp. Laws § 37.2204(d) — 2 cases
Frances Jones Beverly Harder Eleanor Murray Linda Wickel & Mary Ruane v. Cassens Transp. Truck Drivers Local 299, 982 F.2d 983 (6th Cir. 1993). “2204(d), which prohibits labor organizations from: “(d) Fail[ing] to fairly and adequately represent a member in a grievance process because of religion, race, color, national origin, age, sex, height, weight, or marital status.” The language of the collective bargaining…”
Brown v. United Auto., Aerospace & Agric. Implement Workers, Local 892, 682 F. Supp. 901 (E.D. Mich. 1987). “§ 37.2204(d) and M.C.L.A. § 37.-2202(l)(a).”
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