Mich. Comp. Laws » Michigan Compiled Laws / Chapter 423 / Act 336 of 1947
Michigan Compiled Laws

Mich. Comp. Laws § 423.213 (2026)

Decision as to appropriate collective bargaining unit; supervisor of fire fighting personnel.

✓ current as of July 2026
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PUBLIC EMPLOYMENT RELATIONS


Act 336 of 1947


423.213 Decision as to appropriate collective bargaining unit; supervisor of fire fighting personnel.

Sec. 13.

    The commission shall decide in each case, to insure public employees the full benefit of their right to self-organization, to collective bargaining and otherwise to effectuate the policies of this act, the unit appropriate for the purposes of collective bargaining as provided in section 9e of Act No. 176 of the Public Acts of 1939, as amended, being section 423.9e of the Michigan Compiled Laws: Provided, That in any fire department, or any department in whole or part engaged in, or having the responsibility of, fire fighting, no person subordinate to a fire commission, fire commissioner, safety director, or other similar administrative agency or administrator, shall be deemed to be a supervisor.

History: Add. 1965, Act 379, Imd. Eff. July 23, 1965 ;-- Am. 1976, Act 18, Imd. Eff. Feb. 20, 1976

PopularName Notes:

Public Employment Relations
Notes of Decisions
Cited in 31 cases, 1970–2017 · leading case: Grandville Mun. Exec. Ass'n v. City of Grandville, 553 N.W.2d 917 (Mich. 1996).
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Grandville Mun. Exec. Ass'n v. City of Grandville, 553 N.W.2d 917 (Mich. 1996). · cites it 4× “§§ 423.213, 423.9e; M.S.A. §§ 17.455(13), 17.”
LOCAL 1383 v. City of Warren, 311 N.W.2d 702 (Mich. 1981). · cites it 2× “See MCL 423.213; MSA 17.455(13). [3] Compare MCL 123.”
Police Officers Ass'n v. City of Grosse Pointe Farms, 496 N.W.2d 794 (Mich. Ct. App. 1993). · cites it 3× “The poam first contends that the merc erred as a matter of law in its interpretation and application of § 13 of the public employment relations act, MCL 423.213; MSA 17.455(13). The poam asserts that it is clear from the face of the statute that its purpose is to ensure that all…”
Wayne Cnty. Civil Serv. Comm'n v. Bd. of Supervisors, 184 N.W.2d 201 (Mich. 1971). · cites it 2× “is section shall prohibit or restrict a board of county road commissioners who have prior to January 1, 1968 entered into a collective bargaining agreement from participating in a pension or insurance program for those of its employees who are members of a collective bargaining…”
Faust Pub. Library v. Afscme Council 25, 875 N.W.2d 254 (Mich. Ct. App. 2015). “MCL 423.213; Muskegon Co Prof Command Ass’n, 186 Mich App at 369 .”
Livingston Cnty. v. Livingston Circuit Judge, 225 N.W.2d 352 (Mich. 1975). · cites it 2× “MCLA 423.213; MSA 17.455(13). [4] Election supervised by the MERC.”
Detroit Fire Fighters Assoc. v. City of Detroit, 293 N.W.2d 278 (Mich. 1980). “MCL 423.213; MSA 17.455(13). Specific concern for arbitral resolution of fire fighter labor disputes was manifestly signaled *723 when the Legislature enacted the compulsory arbitration of labor disputes in police and fire departments act, MCL 423.”
City of Ishpeming Supervisory Employees' Chapter of Local 128, Michigan Council 25 v. City of Ishpeming, 400 N.W.2d 661 (Mich. Ct. App. 1986). “The city contends that Burke’s duties in his new job were significantly different from the duties in his old job and that he should have been represented by the dpw unit. The city claims that it bargained appropriately regarding the effects of his transfer with the dpw unit.”
United Steelworkers v. City of Frankfort, 395 N.W.2d 318 (Mich. Ct. App. 1986). · cites it 2× “" Under MCL 423.213; MSA 17.455(13), the "unit appropriate" is to be determined by MERC as provided in MCL 423.”
Hillsdale Cmty. Schs. v. Labor Mediation Bd., 179 N.W.2d 661 (Mich. Ct. App. 1970). · cites it 2× “” The legislature designated the MLMB as the agency to determine the appropriate bargaining units, MCLA § 423.213 (Stat Ann 1968 Rev § 17.455 [13]).”
Detroit Bd. of Educ. v. Local 28, Org. of Sch. Administrators & Supervisors, 308 N.W.2d 247 (Mich. Ct. App. 1981). “455(13), the Commission is empowered to determine the appropriate units within which public employees may organize: "The commission shall decide in each case, to insure public employees the full benefit of their right to self-organization, to collective bargaining and otherwise…”
Muskegon Cnty. Prof'l Command Ass'n v. Cnty. of Muskegon, 464 N.W.2d 908 (Mich. Ct. App. 1990). “MCL 423.213; MSA 17.455; Hillsdale, supra, 40 ; Dearborn, supra, 226-227 .”
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