Michigan Compiled Laws
Mich. Comp. Laws § 423.215b (2026)
Repealed. 2023, Act 113, Eff. Feb. 13, 2024.
✓ current as of July 2026
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PUBLIC EMPLOYMENT RELATIONS
Act 336 of 1947
423.215b Repealed. 2023, Act 113, Eff. Feb. 13, 2024.
Repealed. 2023, Act 113, Eff. Feb. 13, 2024.
Compiler's Notes:
The repealed section pertained to the collection of union dues by public school personnel and the freezing of wages and benefits for certain public employees during contract negotiations.
Notes of Decisions
Cited in 8
cases (1 in the last 5 years), 2014–2022 · leading case: Bedford Pub. Schs. v. Bedford Educ. Ass'n, 853 N.W.2d 452 (Mich. Ct. App. 2014).
Bedford Pub. Schs. v. Bedford Educ. Ass'n, 853 N.W.2d 452 (Mich. Ct. App. 2014). “We conclude that MCL 423.215b does not unconstitutionally deprive public employees of any vested right and that MERC correctly applied the statute.”
Van Buren Cnty. Educ. Ass'n & Decatur Educ. Support Pers. Ass'n v. Decatur Pub. Schs., 872 N.W.2d 710 (Mich. Ct. App. 2015). “215b, which was enacted as an amendment to PERA in 2011, provides, in pertinent part: (1) Except as otherwise provided in this section, after the expiration date of a collective bargaining agreement and until a successor collective bargaining agreement is in place, a public…”
Cnty. of Ingham v. Michigan Ass'n of Police (Mich. Ct. App. 2016). “The County maintained that retroactive application of the wage increase is prohibited by MCL 423.215b(2), which states, in pertinent part, that “the parties to a collective bargaining agreement shall not agree to, and an arbitration panel shall not order, any retroactive wage or…”
Bedford Pub. Schs. v. Bedford Educ. Ass'n mea/nea (Mich. 2015). “However, I think that the legislative history of 2011 PA 54 , which enacted MCL 423.215b, is illustrative of the problem that this statute presents.”
Bedford Pub. Schs. v. Bedford Educ. Ass'n mea/nea (Mich. 2015). “However, I think that the legislative history of 2011 PA 54 , which enacted MCL 423.215b, is illustrative of the problem that this statute presents.”
Charles Kaminski v. City of Lincoln Park (Mich. Ct. App. 2022). “” Lincoln Park argues that this language constitutes status-quo language that is consistent with MCL 423.215b(1)3 and does not extend the benefits provided by the 2002 CBA beyond that agreement’s end date in the general durational clause.”
City of Wyandotte v. Police Officers Ass'n of Michigan (Mich. Ct. App. 2015). “” The current dispute centers on the healthcare cost provision of the CBA.”
Angela Steffke v. Taylor Fed'n of Teachers (Mich. Ct. App. 2015). “Plaintiffs contend that the union security agreement is illegal under the PERA, MCL 423.215b, because it contains a benefit “meant to extend beyond the terms of the collective bargaining agreement.”
— Mich. Comp. Laws § 423.215b(1) — 4 cases
Bedford Pub. Schs. v. Bedford Educ. Ass'n mea/nea (Mich. 2015). “However, I think that the legislative history of 2011 PA 54 , which enacted MCL 423.215b, is illustrative of the problem that this statute presents.”
Bedford Pub. Schs. v. Bedford Educ. Ass'n mea/nea (Mich. 2015). “However, I think that the legislative history of 2011 PA 54 , which enacted MCL 423.215b, is illustrative of the problem that this statute presents.”
Charles Kaminski v. City of Lincoln Park (Mich. Ct. App. 2022). “” Lincoln Park argues that this language constitutes status-quo language that is consistent with MCL 423.215b(1)3 and does not extend the benefits provided by the 2002 CBA beyond that agreement’s end date in the general durational clause.”
City of Wyandotte v. Police Officers Ass'n of Michigan (Mich. Ct. App. 2015). “” The current dispute centers on the healthcare cost provision of the CBA.”
— Mich. Comp. Laws § 423.215b(2) — 1 case
Cnty. of Ingham v. Michigan Ass'n of Police (Mich. Ct. App. 2016). “The County maintained that retroactive application of the wage increase is prohibited by MCL 423.215b(2), which states, in pertinent part, that “the parties to a collective bargaining agreement shall not agree to, and an arbitration panel shall not order, any retroactive wage or…”
— Mich. Comp. Laws § 423.215b(3) — 1 case
Bedford Pub. Schs. v. Bedford Educ. Ass'n, 853 N.W.2d 452 (Mich. Ct. App. 2014). “We conclude that MCL 423.215b does not unconstitutionally deprive public employees of any vested right and that MERC correctly applied the statute.”
— Mich. Comp. Laws § 423.215b(4)(b) — 1 case
City of Wyandotte v. Police Officers Ass'n of Michigan (Mich. Ct. App. 2015). “” The current dispute centers on the healthcare cost provision of the CBA.”
— Mich. Comp. Laws § 423.215b(4)(c) — 1 case
Cnty. of Ingham v. Michigan Ass'n of Police (Mich. Ct. App. 2016). “The County maintained that retroactive application of the wage increase is prohibited by MCL 423.215b(2), which states, in pertinent part, that “the parties to a collective bargaining agreement shall not agree to, and an arbitration panel shall not order, any retroactive wage or…”
— Mich. Comp. Laws § 423.215b(l) — 2 cases
Bedford Pub. Schs. v. Bedford Educ. Ass'n, 853 N.W.2d 452 (Mich. Ct. App. 2014). “We conclude that MCL 423.215b does not unconstitutionally deprive public employees of any vested right and that MERC correctly applied the statute.”
Van Buren Cnty. Educ. Ass'n & Decatur Educ. Support Pers. Ass'n v. Decatur Pub. Schs., 872 N.W.2d 710 (Mich. Ct. App. 2015). “215b, which was enacted as an amendment to PERA in 2011, provides, in pertinent part: (1) Except as otherwise provided in this section, after the expiration date of a collective bargaining agreement and until a successor collective bargaining agreement is in place, a public…”
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