Mo. Rev. Stat. » Chapter 105
Missouri Revised Statutes

Mo. Rev. Stat. § 105.510 (2026)

Certain public employees may join labor organizations and bargain collectively

✓ current as of May 2026
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  105.510.  Certain public employees may join labor organizations and bargain collectively — exceptions — discharge or discrimination for exercise of right prohibited — allowable organizations for excepted employees. — Employees, except police, deputy sheriffs, Missouri state highway patrolmen, Missouri National Guard, all teachers of all Missouri schools, colleges and universities, of any public body shall have the right to form and join labor organizations and to present proposals to any public body relative to salaries and other conditions of employment through the representative of their own choosing.  No such employee shall be discharged or discriminated against because of his exercise of such right, nor shall any person or group of persons, directly or indirectly, by intimidation or coercion, compel or attempt to compel any such employee to join or refrain from joining a labor organization, except that the above excepted employees have the right to form benevolent, social, or fraternal associations.  Membership in such associations may not be restricted on the basis of race, creed, color, religion or ancestry.

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(L. 1965 p. 232 § 2, A.L. 1967 p. 192, A.L. 1969 S.B. 36)

(1969) The exclusion of certain public employees from the benefits of sections 105.500 to 105.530, RSMo, is not an arbitrary and unconstitutional classification. State ex rel. Missey v. City of Cabool (Mo.), 441 S.W.2d 35.

(1974) Teachers' association held not a labor union for the purpose of this section. Agreement involved in this case held not prohibited by this section. Peters v. Board of Education of Reorg. Sch. Dist. No. 5 (Mo.), 506 S.W.2d 429.

(1977) Teachers' strike while not covered by statute is illegal as violative of common law. School Dist. of Kansas City v. Clymer (A.), 554 S.W.2d 483.

(1983) Omission of firefighters from "meet and confer" provisions of this section and the inclusion of police officers has a rational basis and therefore does not violate the equal protection clause of the 14th Amendment of the U.S. Constitution.  Melvin Beverlin, et al. v. Board of Police Commissioners of Kansas City, Missouri, 722 F.2d 395.

(1985) County corrections officers are not "police officers" or "deputy sheriffs" for purposes of this statute. Jackson County v. Mo. State Board of Mediation (Mo. banc), 690 S.W.2d 400.

(1993) Requiring nonunion school custodial and food service workers to pay fair share fees to union which is properly designated as exclusive bargaining representative does not violate provision of statute that prohibits conduct that directly or indirectly compels public employees to join or refrain from joining labor organization. Schaffer v. Board of Education of the City of St. Louis, 869 S.W.2d 163 (Mo. App. E.D.)

Notes of Decisions
Cited in 53 cases (4 in the last 5 years), 1969–2024 · leading case: Missouri Nat'l Educ. Ass'n v. Missouri State Bd. of Mediation, 695 S.W.2d 894 (Mo. 1985).
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Missouri Nat'l Educ. Ass'n v. Missouri State Bd. of Mediation, 695 S.W.2d 894 (Mo. 1985). · cites it 28× “Although § 105.510, RSMo 1978, uses the word "employees" without additional specificity in describing the composition of a bargaining unit, the legislature did not intend for all persons on the public payroll to be considered employees for bargaining purposes.”
Indep.-Nat'l Educ. Ass'n v. Indep. Sch. Dist., 223 S.W.3d 131 (Mo. 2007). · cites it 16× “" Section 105.510. The public sector labor law excludes "all teachers of all Missouri schools.”
Vorbeck v. McNeal, 407 F. Supp. 733 (E.D. Mo. 1976). · cites it 34× “These two consolidated lawsuits once again raise the constitutionality of the Missouri Public Sector Labor Law, Sections 105.510 through 105.530, R.S.Mo.”
Strunk v. Hahn, 797 S.W.2d 536 (Mo. Ct. App. 1990). · cites it 16× “ON MOTION FOR REHEARING OR TRANSFER By motion for rehearing, or alternatively to transfer, the Union again vociferously argues that there is a compelling need to resolve the question of whether § 105.510, RSMo 1986, permits or precludes agency shop provisions as a lawful issue…”
St. Louis Police Leadership Org. v. City of St. Louis, 484 S.W.3d 882 (Mo. Ct. App. 2016). · cites it 10× “Section 105.510 1 The procedural collective bargaining framework for most public employees in the State of Missouri is established by the State Board of Mediation.”
E. Missouri Coalition of Police, Fraternal Order of Police, Lodge 15 v. City of Chesterfield, 386 S.W.3d 755 (Mo. 2012). · cites it 7× “Section 105.510. This Court’s decision in Independence-Nat’l Educ.”
Schaffer v. Bd. of Educ. of St. Louis, 869 S.W.2d 163 (Mo. Ct. App. 1993). · cites it 10× “They alleged the fair share provision violated § 105.510 2 relating to public employees collective bargaining and § 432.”
Am. Fed'n of Teachers v. Ledbetter, 387 S.W.3d 360 (Mo. 2012). · cites it 4× “Section 105.510. When a procedural framework for bargaining is not codified, i.”
Strinni v. Mehlville Fire Prot. Dist., 681 F. Supp. 2d 1052 (E.D. Mo. 2010). · cites it 8× “of the Missouri Revised Statutes for Defendants' alleged violations of Sections 8, 9, and 29 of Article I of the Missouri constitution (Count III) and alleged violations of Section 105.510 of the Missouri Revised Statutes (Count IV).”
West Cent. Missouri Region Lodge 50 of The Fraternal Order of Police v. The city of Grandview, Missouri, 460 S.W.3d 425 (Mo. Ct. App. 2015). · cites it 11× “Section 105.510, RSMo 2000, of the Missouri public sector labor law provides: Employees, except police, deputy sheriffs, Missouri state highway patrolmen, Missouri National Guard, all teachers of all Missouri schools, colleges and universities, of any public body shall have the…”
Sumpter v. City of Moberly, 645 S.W.2d 359 (Mo. 1983). · cites it 6× “That organization, as authorized by § 105.510, [2] presented proposals relative to salaries and other conditions of employment to the City of Moberly.”
Jackson Cnty. v. Missouri State Bd. of Mediation, 690 S.W.2d 400 (Mo. 1985). · cites it 9× “Section 105.510, RSMo 1978, of the Missouri Public Sector Labor Law bars police and deputy sheriffs, among others, from exercising the limited bargaining rights which the statute grants to other public employees.”
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