Missouri Revised Statutes

Mo. Rev. Stat. § 105.500 (2026)

Definitions

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  105.500.  Definitions. — For purposes of sections 105.500 to 105.598, unless the context otherwise requires, the following words and phrases mean:

  (1)  "Bargaining unit", a unit of public employees at any plant or installation or in a craft or in a function of a public body that establishes a clear and identifiable community of interest among the public employees concerned;

  (2)  "Board", the state board of mediation established under section 295.030;

  (3)  "Department", the department of labor and industrial relations established under section 286.010;

  (4)  "Exclusive bargaining representative", an organization that has been designated or selected, as provided in section 105.575, by a majority of the public employees in a bargaining unit as the representative of such public employees in such unit for purposes of collective bargaining;

  (5)  "Labor organization", any organization, agency, or public employee representation committee or plan, in which public employees participate and that exists for the purpose, in whole or in part, of dealing with a public body or public bodies concerning collective bargaining, grievances, labor disputes, wages, rates of pay, hours of employment, or conditions of work;

  (6)  "Public body", the state of Missouri, or any officer, agency, department, bureau, division, board or commission of the state, or any other political subdivision or special district of or within the state.  Public body shall not include the department of corrections;

  (7)  "Public employee", any person employed by a public body;

  (8)  "Public safety labor organization", a labor organization wholly or primarily representing persons trained or authorized by law or rule to render emergency medical assistance or treatment, including, but not limited to, firefighters, emergency medical technicians, dispatchers, registered nurses and physicians, and persons who are vested with the power of arrest for criminal code violations including, but not limited to, police officers, sheriffs, and deputy sheriffs.

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(L. 1965 p. 232 § 1, A.L. 1967 p. 192, A.L. 2018 H.B. 1413, A.L. 2023 H.B. 402 merged with S.B. 24)

(1974) Employees of judicial department paid either by state or county are within the provisions of this section. State ex rel. O'Leary v. Missouri State Board of Mediation (Mo.), 509 S.W.2d 84.

(2021)  House Bill 1413 enacted in 2018 held invalid as violation of equal protection clause of Article I, Section 2 of state constitution; section as amended by that act could not be severed from rest of bill.  Missouri National Education Association v. Missouri Department of Labor and Industrial Relations, 623 S.W.3d 585 (Mo.banc).

Notes of Decisions
Cited in 43 cases (5 in the last 5 years), 1969–2023 · leading case: Indep.-Nat'l Educ. Ass'n v. Indep. Sch. Dist., 223 S.W.3d 131 (Mo. 2007).
Indep.-Nat'l Educ. Ass'n v. Indep. Sch. Dist., 223 S.W.3d 131 (Mo. 2007). · cites it 20× “These associations are certified as the exclusive bargaining representatives for their respective employees pursuant to Missouri's public sector labor law; section 105.500, et seq. [1] The Independence-National Education Association represents the district's teachers and…”
State Ex Inf. Ashcroft v. Kansas City Firefighters Local No. 42, 672 S.W.2d 99 (Mo. Ct. App. 1984). · cites it 7× “530 provides: “Nothing contained in sections 105.500 to 105.530 [the Public Sector Labor Law] shall be construed as granting a right to employees covered in sections 105.”
Sumpter v. City of Moberly, 645 S.W.2d 359 (Mo. 1983). · cites it 8× “1969), stated that §§ 105.500 to 105.530 are in accord with the constitutional principles previously enumerated in Clouse .”
Missouri Nat'l Educ. Ass'n v. Missouri State Bd. of Mediation, 695 S.W.2d 894 (Mo. 1985). · cites it 6× “The MNEA petitioned the Board pursuant to the Public Sector Labor Law, §§ 105.500, et seq., RSMo 1978, for certification as exclusive bargaining representative of all clerical employees, teacher aides and school nurses employed by the District.”
Am. Fed'n of Teachers v. Ledbetter, 387 S.W.3d 360 (Mo. 2012). · cites it 4× “Missouri’s public sector labor law, codified in section 105.500, et seq., creates a procedural framework for collective bargaining for public employees, but it expressly excludes certain professions, including law enforcement officers and teachers.”
E. Missouri Coalition of Police v. City of Chesterfield, 386 S.W.3d 755 (Mo. 2012). · cites it 6× “University City and Chesterfield are not excused from carrying out this duty because the public employees represented by the union are not covered by the procedures codified in the public sector labor law, section 105.500, et seq., RSMo. 1 Each city has the ability to establish…”
City of Cabool v. Missouri State Bd. of Mediation, 689 S.W.2d 51 (Mo. 1985). · cites it 4× “With regard to the principles of law involved in the present case, the city suggests, somewhat obliquely, that federal law provides authority for the proposition that supervisors are not within the ambit of the term "employee" as it is used in the Missouri Public Sector Labor…”
State ex rel. O'Leary v. Missouri State Bd. of Mediation, 509 S.W.2d 84 (Mo. 1974). · cites it 9× “f Cole County, Missouri, a petition filed by a union, the Western Missouri Public Employees Local 1812, wherein said union seeks to establish that it has majority representative status with certain employees of the Juvenile Division of the Jackson County Circuit Court and is…”
Kinder v. Holden, 92 S.W.3d 793 (Mo. Ct. App. 2002). · cites it 3× “In 1965, the Missouri General Assembly enacted the Public Sector Labor Law, § 105.500 RSMo 1 et seq., which provides that public employees, excluding certain professions, have “the right to form and join labor organizations and to present proposals to any public body relative to…”
Cates v. Webster, 727 S.W.2d 901 (Mo. 1987). · cites it 4× “510, RSMo 1969, concerning labor organizations, where § 105.500(3), RSMo 1969, defined "public body" as "the state of Missouri, or any officer, agency, department, bureau, division, board or commission of the state, or any other political subdivision of or within the state.”
State ex rel. Missey v. City of Cabool, 441 S.W.2d 35 (Mo. 1969). · cites it 4× “166 (Sections 105.500 to 105.530, V.A.M.S.), which amended and re-enacted existing law enacted in 1965 to provide, among other things: that “Employees except police, deputy sheriffs, Missouri state highway patrolmen, Missouri national guard, all teachers of all Missouri schools,…”
Strinni v. Mehlville Fire Prot. Dist., 681 F. Supp. 2d 1052 (E.D. Mo. 2010). · cites it 3× “With respect to Plaintiffs' statutory claim under Missouri Revised Statutes § 105.”
Mo. Rev. Stat. § 105.500(1): 5 cases
City of Cabool v. Missouri State Bd. of Mediation, 689 S.W.2d 51 (Mo. 1985). “With regard to the principles of law involved in the present case, the city suggests, somewhat obliquely, that federal law provides authority for the proposition that supervisors are not within the ambit of the term "employee" as it is used in the Missouri Public Sector Labor…”
City of Kirkwood v. Missouri State Bd. of Mediation, 478 S.W.2d 690 (Mo. Ct. App. 1972).
Pike Cnty. Mem'l Hosp. v. Birch, 144 S.W.3d 905 (Mo. Ct. App. 2004).
Mo. Rev. Stat. § 105.500(2): 3 cases
Indep.-Nat'l Educ. Ass'n v. Indep. Sch. Dist., 162 S.W.3d 18 (Mo. Ct. App. 2005).
Schaffer v. Bd. of Educ. of St. Louis, 869 S.W.2d 163 (Mo. Ct. App. 1993).
City of Kirkwood v. Missouri State Bd. of Mediation, 478 S.W.2d 690 (Mo. Ct. App. 1972).
Mo. Rev. Stat. § 105.500(3): 3 cases
Cates v. Webster, 727 S.W.2d 901 (Mo. 1987). “510, RSMo 1969, concerning labor organizations, where § 105.500(3), RSMo 1969, defined "public body" as "the state of Missouri, or any officer, agency, department, bureau, division, board or commission of the state, or any other political subdivision of or within the state.”
State ex rel. O'Leary v. Missouri State Bd. of Mediation, 509 S.W.2d 84 (Mo. 1974). “f Cole County, Missouri, a petition filed by a union, the Western Missouri Public Employees Local 1812, wherein said union seeks to establish that it has majority representative status with certain employees of the Juvenile Division of the Jackson County Circuit Court and is…”
Wrinkle v. Int'l Union of Operating Engineers, Local 2, 867 S.W.2d 633 (Mo. Ct. App. 1993).
Mo. Rev. Stat. § 105.500(5): 1 case
Mo. Rev. Stat. § 105.500(6): 1 case
Mo. Rev. Stat. § 105.500(8): 1 case
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