Michigan Compiled Laws

Mich. Comp. Laws § 423.209 (2026)

Public employees; rights; labor organization.

✓ current as of July 2026

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PUBLIC EMPLOYMENT RELATIONS

Act 336 of 1947

423.209 Public employees; rights; labor organization.

Sec. 9.

Public employees may organize together or form, join, or assist in labor organizations; engage in lawful concerted activities for the purpose of collective negotiation or bargaining or other mutual aid and protection; or negotiate or bargain collectively with their public employers through representatives of their own free choice.

History: Add. 1965, Act 379, Imd. Eff. July 23, 1965 ;-- Am. 2012, Act 349, Eff. Mar. 28, 2013 ;-- Am. 2014, Act 414, Imd. Eff. Dec. 30, 2014 ;-- Am. 2023, Act 9, Eff. Feb. 13, 2024

Compiler's Notes:

Enacting section 1 of Act 349 of 2012 provides:

"Enacting section 1. If any part or parts of this act are found to be in conflict with the state constitution of 1963, the United States constitution, or federal law, this act shall be implemented to the maximum extent that the state constitution of 1963, the United States constitution, and federal law permit. Any provision held invalid or inoperative shall be severable from the remaining portions of this act."

Enacting section 1 of Act 414 of 2014 provides:

"Enacting section 1. If any part or parts of this act are found to be in conflict with the state constitution of 1963, the United States constitution, or federal law, this act shall be implemented to the maximum extent that the state constitution of 1963, the United States constitution, and federal law permit. Any provision held invalid or inoperable shall be severable from the remaining portions of this act."

PopularName Notes:

Public Employment Relations

Notes of Decisions

Cited in 64 cases (1 in the last 5 years), 1969–2024 · leading case: Bank v. Michigan Educ. Ass'n-Nea, 892 N.W.2d 1 (Mich. Ct. App. 2016).

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Bank v. Michigan Educ. Ass'n-Nea, 892 N.W.2d 1 (Mich. Ct. App. 2016). · cites it 8× “, MCL 423.209].” Plaintiffs claims particularly pertain to the rights contained in MCL 423.”

Michigan Educ. Ass'n v. Sec'y of State, 489 Mich. 194 (Mich. 2010). · cites it 5× “477(1) and MCL 423.209, which grants authority for public employees to engage in collective bargaining, are “considered in tandem,” they “ ‘expressly or impliedly grant’ school districts the authority to enter collective-bargaining agreements that require a school district to…”

Michigan Emp. Relations Comm'n v. Reeths-Puffer Sch. Dist., 215 N.W.2d 672 (Mich. 1974). · cites it 6× “" The rights guaranteed are found in MCLA 423.209; MSA 17.455(9): "It shall be lawful for public employees to organize together or to form, join or assist in labor organizations, to engage in lawful concerted activities for the purpose of collective negotiation or bargaining or…”

UAW v. Green, 302 Mich. App. 246 (Mich. Ct. App. 2013). · cites it 5× “2 states that a governmental employer may enter into an agreement with a union which provides that “as a condition of continued employment,” an employee who chooses not to join the union “shall pay a service fee” to the union.”

Demings v. City of Ecorse, 377 N.W.2d 275 (Mich. 1985). · cites it 4× “The rights guaranteed in § 9, MCL 423.209; MSA 17.455(9), are: It shall be lawful for public employees to organize together or to form, join or assist in labor organizations, to engage in lawful concerted activities for the purpose of collective negotiation or bargaining or…”

Goolsby v. City of Detroit, 358 N.W.2d 856 (Mich. 1984). · cites it 2× “455(7)(1), MCL 423.209; MSA 17.455(9), MCL 423.211; MSA 17.”

Seiu Health Care Michigan v. Snyder, 875 F. Supp. 2d 710 (E.D. Mich. 2012). · cites it 4× “Mich. Comp. Laws § 423.209 . A public employee is: A person holding a position by appointment or employment in the government of this state, in the government of 1 or more of the political subdivisions of this state, in the public school service, in a public or special district,…”

Southfield Police Officers Ass'n v. Southfield, 445 N.W.2d 98 (Mich. 1989). · cites it 2× “III Under § 9 of the PERA, MCL 423.209; MSA 17.455(9), public employees enjoy the right to organize and engage in collective bargaining.”

Wayne Cnty. v. Afscme Local 3317, 928 N.W.2d 709 (Mich. Ct. App. 2018). “210(1) provides: A public employer or an officer or agent of a public employer shall not do any of the following: (a) Interfere with, restrain, or coerce public employees in the exercise of their rights guaranteed in [MCL 423.209 ]. (b) Initiate, create, dominate, contribute to,…”

Judges of the 74th Jud. Dist. v. Bay Cnty., 190 N.W.2d 219 (Mich. 1971). · cites it 2× “It is charged here that one of the judges threatened a court employee with dismissal if she exercised her right under MCLA § 423.209 (Stat Ann 1968 Rev § 17.455 [9]) to join the Union.”

Van Buren Pub. Sch. Dist. v. Wayne Circuit Judge, 232 N.W.2d 278 (Mich. Ct. App. 1975). · cites it 2× “MCLA 423.209; MSA 17.455(9). Section 10(a) of PERA adopts word-for-word the *35 analogous provision 22 of the NLRA.”

Ingham Cnty. v. Capitol City Lodge No 141 of the Fraternal Order of Police, Labor Prog., Inc, 739 N.W.2d 95 (Mich. Ct. App. 2007). · cites it 4× “157, which is the federal counterpart to § 9 of PERA, MCL 423.209. In its analysis, the United States Court of Appeals for the First Circuit adopted *107 and applied the three-part test set forth in Jeannette Corp.”

Show all 64 citing cases →

— Mich. Comp. Laws § 423.209(1) — 3 cases

Detroit Hous. Comm'n v. Neil Sweat (Mich. Ct. App. 2016).

Standish-Sterling Educ. Support Pers. v. Mark Norgan (Mich. Ct. App. 2017).

— Mich. Comp. Laws § 423.209(1)(a) — 5 cases

Standish-Sterling Educ. Support Pers. v. Mark Norgan (Mich. Ct. App. 2017).

Teamsters Local 214 v. Pauline Beutler (Mich. Ct. App. 2017).

Interurban Transit P'ship v. Amalgamated Transit Union (Mich. Ct. App. 2018).

Ann Arbor Educ. Ass'n v. Jeffrey L Finnan (Mich. Ct. App. 2019).

— Mich. Comp. Laws § 423.209(1)(b) — 4 cases

Taylor Sch. Dist. v. Nancy Rhatigan (Mich. Ct. App. 2016).

Standish-Sterling Educ. Support Pers. v. Mark Norgan (Mich. Ct. App. 2017).

Ann Arbor Educ. Ass'n v. Jeffrey L Finnan (Mich. Ct. App. 2019).

— Mich. Comp. Laws § 423.209(2) — 6 cases

Bank v. Michigan Educ. Ass'n-Nea, 892 N.W.2d 1 (Mich. Ct. App. 2016). “, MCL 423.209].” Plaintiffs claims particularly pertain to the rights contained in MCL 423.”

UAW v. Green, 302 Mich. App. 246 (Mich. Ct. App. 2013). “2 states that a governmental employer may enter into an agreement with a union which provides that “as a condition of continued employment,” an employee who chooses not to join the union “shall pay a service fee” to the union.”

Ann Arbor Educ. Ass'n v. Jeffrey L Finnan (Mich. Ct. App. 2019).

Standish-Sterling Educ. Support Pers. v. Mark Norgan (Mich. Ct. App. 2017).

— Mich. Comp. Laws § 423.209(2)(a) — 6 cases

Standish-Sterling Educ. Support Pers. v. Mark Norgan (Mich. Ct. App. 2017).

Taylor Sch. Dist. v. Nancy Rhatigan (Mich. Ct. App. 2016).

Teamsters Local 214 v. Tina House (Mich. Ct. App. 2017).

— Mich. Comp. Laws § 423.209(3) — 4 cases

Bank v. Michigan Educ. Ass'n-Nea, 892 N.W.2d 1 (Mich. Ct. App. 2016). “, MCL 423.209].” Plaintiffs claims particularly pertain to the rights contained in MCL 423.”

Ann Arbor Educ. Ass'n v. Jeffrey L Finnan (Mich. Ct. App. 2019).

Standish-Sterling Educ. Support Pers. v. Mark Norgan (Mich. Ct. App. 2017).

— Mich. Comp. Laws § 423.209(l)(a) — 1 case

— Mich. Comp. Laws § 423.209(l)(b) — 1 case

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