Michigan Compiled Laws
Mich. Comp. Laws § 423.28 (2026)
Determination of appropriate unit for collective bargaining.
✓ current as of July 2026
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EMPLOYMENT RELATIONS COMMISSION
Act 176 of 1939
423.28 Determination of appropriate unit for collective bargaining.
Sec. 28.
The commission shall decide in each case, in order to insure 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.
History: Add. 1965, Act 282, Imd. Eff. July 22, 1965 ;-- Am. 1976, Act 17, Imd. Eff. Feb. 20, 1976
Notes of Decisions
Cited in 4
cases, 1972–1998 · leading case: Michigan Educ. Ass'n v. Alpena Cmty. Coll., 577 N.W.2d 457 (Mich. 1998).
Michigan Educ. Ass'n v. Alpena Cmty. Coll., 577 N.W.2d 457 (Mich. 1998). “§ 423.28; M.S.A. § 17.454(30).] [6] Salem Hotel Corp v.”
Local 547, Int'l Union of Operating Engineers v. Henry Ford Hosp., 229 N.W.2d 925 (Mich. Ct. App. 1975). “MERC is provided with sufficient discretionary authority to utilize its expertise in selecting appropriate bargaining units to effectuate the broad policies of the law, as well as to insure employee collective bargaining rights.”
Fraternal Order of Police v. Michigan State Univ., 233 N.W.2d 75 (Mich. Ct. App. 1975). “The statute, MCLA 423.28; MSA 17.454(30) vests MERC with broad discretionary authority in its determination of what constitutes an appropriate bargaining unit.”
ED DeVries & Sons v. Emp. Relations Comm'n, 195 N.W.2d 784 (Mich. Ct. App. 1972). “MCLA 423.28; MSA 17.454(30). 3 During the course of the hearing both unions offered to represent a single unit jointly.”
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