Mich. Comp. Laws » Michigan Compiled Laws / Chapter 423 / Act 176 of 1939
Michigan Compiled Laws

Mich. Comp. Laws § 423.9e (2026)

Bargaining unit.

✓ current as of July 2026
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EMPLOYMENT RELATIONS COMMISSION


Act 176 of 1939


423.9e Bargaining unit.

Sec. 9e.

    The commission, after consultation with the parties, shall determine such a bargaining unit as will best secure to the employees their right of collective bargaining. The unit shall be either the employees of 1 employer employed in 1 plant or business enterprise within this state, not holding executive or supervisory positions, or a craft unit, or a plant unit, or a subdivision of any of the foregoing units. If the group of employees involved in the dispute was recognized by the employer or identified by certification, contract, or past practice, as a unit for collective bargaining, the commission may adopt that unit.

History: Add. 1947, Act 318, Eff. Oct. 11, 1947 ;-- CL 1948, 423.9e ;-- Am. 1965, Act 282, Imd. Eff. July 22, 1965 ;-- Am. 1976, Act 17, Imd. Eff. Feb. 20, 1976

Notes of Decisions
Cited in 26 cases, 1952–2017 · 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 10× “176 of the Public Acts of 1939, as amended, being section 423.9e of the Michigan Compiled Laws.”
Police Officers Ass'n v. City of Grosse Pointe Farms, 496 N.W.2d 794 (Mich. Ct. App. 1993). · cites it 6× “Additionally, MCL 423.9e; MSA 17.454(10.4), referred to in § 13 above, provides as follows: The commission, after consultation with the parties, shall determine such a bargaining unit as will best secure to the employees their right of collective bargaining.”
United Steelworkers v. City of Frankfort, 395 N.W.2d 318 (Mich. Ct. App. 1986). · cites it 5× “455(13), the "unit appropriate" is to be determined by MERC as provided in MCL 423.9e; MSA 17.454(10.4), which states: The commission, after consultation with the parties, shall determine such a bargaining unit as will best secure to the employees their right of collective…”
Michigan State AFL-CIO v. Emp. Relations Comm'n, 551 N.W.2d 165 (Mich. 1996). · cites it 2× “§ 423.9e; M.S.A. § 17.454(10.4) (regulating the composition of bargaining units), M.”
Detroit Bd. of Educ. v. Local 28, Org. of Sch. Administrators & Supervisors, 308 N.W.2d 247 (Mich. Ct. App. 1981). · cites it 2× “176 of the Public Acts of 1939, as amended, being section 423.9e of the Michigan Compiled Laws * * .”
Michigan Educ. Support Pers. Ass'n v. Southfield Pub. Schs., 384 N.W.2d 768 (Mich. Ct. App. 1985). · cites it 2× “Pursuant to MCL 423.9e; MSA 17.454(10.4). the task of determining an appropriate collective bargaining unit is left to MERC.”
Muskegon Cnty. Prof'l Command Ass'n v. Cnty. of Muskegon, 464 N.W.2d 908 (Mich. Ct. App. 1990). · cites it 2× “The Legislature has delegated to the commission the power to determine appropriate units for collective bargaining as provided in MCL 423.9e; MSA 17.454(10.4) of the labor mediation act (lma).”
Michigan Educ. Ass'n v. Alpena Cmty. Coll., 577 N.W.2d 457 (Mich. 1998). · cites it 4× “§ 423.9e; M.S.A. § 17.454(10.4).] 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…”
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 claims that it bargained appropriately regarding the effects of his transfer with the dpw unit.”
Hillsdale Cmty. Schs. v. Labor Mediation Bd., 179 N.W.2d 661 (Mich. Ct. App. 1970). · cites it 2× “The determination of the bargaining unit is based upon criteria set forth in PA 1939, No 176, § 9e as last amended by PA 1965, No 282, MCLA § 423.9e (Stat Ann 1968 Rev § 17.454[10.”
Michigan Educ. Ass'n v. Clare-Gladwin Intermediate Sch. Dist., 396 N.W.2d 538 (Mich. Ct. App. 1986). “455(13), of the public employment relations act the "unit appropriate” for collective bargaining purposes is to be determined by the merc as provided in §9e of the Michigan labor mediation act, MCL 423.9e; MSA 17.454(10.4), which states: The commission, after consultation with…”
Gen. Teamsters Union, Local No. 406 v. Uptown Cleaners & Hatters, Inc., 97 N.W.2d 593 (Mich. 1959). “Upon amendment, 61 Stats 140, 141, section 8 was expanded, alphabetical and numerical subsections being designated.”
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