Michigan Compiled Laws

Mich. Comp. Laws § 423.231 (2026)

Compulsory arbitration in police and fire departments; policy.

✓ current as of July 2026
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COMPULSORY ARBITRATION OF LABOR DISPUTES IN POLICE AND FIRE DEPARTMENTS


Act 312 of 1969


423.231 Compulsory arbitration in police and fire departments; policy.

Sec. 1.

    It is the public policy of this state that in public police and fire departments, where the right of employees to strike is by law prohibited, it is requisite to the high morale of such employees and the efficient operation of such departments to afford an alternate, expeditious, effective and binding procedure for the resolution of disputes, and to that end the provisions of this act, providing for compulsory arbitration, shall be liberally construed.

History: 1969, Act 312, Eff. Oct. 1, 1969

Constitutionality Notes:

    This section does not unconstitutionally divest home-rule cities of their constitutional powers, nor does it surrender the power to tax to the arbitrators in violation of the Michigan Constitution. Dearborn Firefighters Union, Local No 412, IAFF v City of Dearborn, 394 Mich 229; 231 NW2d 226 (1975).

    Act No. 312 of the Public Acts of 1969, as amended by 1976 PA 84, which provides for compulsory arbitration of disputes concerning contract formation in police and fire departments, is a constitutional delegation of legislative power. City of Detroit v Detroit Police Officers Association, 408 Mich 410; 294 NW2d 68 (1980).

    This act, which provides for compulsory arbitration of labor disputes in municipal police and fire departments, is a constitutional delegation of legislative power, providing standards as reasonably precise as the subject matter requires or permits and adequate political accountability. Local 1277, Metropolitan Council No 23, American Federation of State, County and Municipal Employees, AFL-CIO v City of Center Line, 414 Mich 642; 327 NW2d 822 (1982).

PopularName Notes:

Act 312
Notes of Decisions
Cited in 75 cases (2 in the last 5 years), 1972–2023 · leading case: City of Detroit v. Detroit Police Officers Ass'n, 294 N.W.2d 68 (Mich. 1980).
City of Detroit v. Detroit Police Officers Ass'n, 294 N.W.2d 68 (Mich. 1980). · cites it 18× “MCL 423.231 et seq.; MSA 17.455(31) et seq.”
Metro. Council No 23 v. Oakland Cnty. Prosecutor, 294 N.W.2d 578 (Mich. 1980). · cites it 12× “MCL 423.231 et seq.; MSA 17.455(31) et seq.”
Dearborn Fire Fighters Union Local No 412 v. City of Dearborn, 231 N.W.2d 226 (Mich. 1975). · cites it 13× “In each of the consolidated cases this Court is called upon to examine issues concerning the constitutional validity of 1969 PA 312 (MCLA 423.231 et seq.; MSA 17.455 [31] et seq.”
Detroit Fire Fighters Ass'n v. City of Detroit, 753 N.W.2d 579 (Mich. 2008). · cites it 6× “” MCL 423.231 (emphasis added). 4 being appointed,3 conclude the hearing within 30 days of its commencement,4 and issue a written opinion within 30 days of the conclusion of the hearing.”
Ottawa Cnty. v. Jaklinski, 377 N.W.2d 668 (Mich. 1985). · cites it 6× “1969 PA 312 , MCL 423.231; MSA 17.455(31). After "Act 312" interest arbitration is invoked, neither party to the dispute may alter existing "wages, hours, [or] other conditions of employment" without the consent of the other during the pendency of proceedings before the…”
Pontiac Fire Fighters Union Local 376 v. City of Pontiac, 753 N.W.2d 595 (Mich. 2008). · cites it 2× “" It also asked for and received from the court an injunction to maintain the status quo pending compulsory arbitration under Act 312, MCL 423.231 et seq. But no Act 312 arbitration was actually pending when the circuit court issued the injunction.”
Southfield Police Officers Ass'n v. Southfield, 445 N.W.2d 98 (Mich. 1989). · cites it 4× “The public employer must first engage in, and exhaust, either arbitration or a fact-finding procedure established by 1969 PA 312 , MCL 423.231 et seq. ; MSA 17.455(31) et seq.”
Local 1277, Metro. Council No. 23, Am. Fed'n of State Employees v. City of Ctr. Line, 327 N.W.2d 822 (Mich. 1982). · cites it 3× “MCL 423.231 et seq.; MSA 17.455(31) et seq.”
City of Grand Rapids v. Grand Rapids Lodge No 97, Fraternal Order of Police, 330 N.W.2d 52 (Mich. 1982). · cites it 3× “” This provision was the subject of compulsory arbitration pursuant to Act 312, 1969 PA 312 ; MCL 423.231 et seq.; MSA 17.455(31) et seq.”
Detroit Fire Fighters Assoc. v. City of Detroit, 293 N.W.2d 278 (Mich. 1980). · cites it 3× “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 423.231 et seq.; MSA 17.455(31) et seq.”
Pontiac Police Officers Ass'n v. City of Pontiac, 246 N.W.2d 831 (Mich. 1976). · cites it 2× “[23] We appreciate that by reason of the act of the Legislature providing for compulsory arbitration of police and fire department disputes ( 1969 PA 312 ; MCLA 423.231 et seq.; MSA 17.455[31] et seq.”
Joseph Boulton v. Christopher Swanson, 795 F.3d 526 (6th Cir. 2015). “See Mich. Comp. Laws 423.231, et seq. At the arbitration, Under-sheriff Swanson testified regarding Taser, firearm, and CPR training for employees of the Sheriffs Office.”
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