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Missouri Revised Statutes

Mo. Rev. Stat. § 105.570 (2026)

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  *105.570.  Supervisory public employees, separate bargaining unit — labor organization not to represent nonsupervisory and supervisory public employees — definition. — 1.  Supervisory public employees shall not be included within the same bargaining unit as the public employees they supervise.

  2.  The same labor organization shall not represent both nonsupervisory and supervisory public employees.

  3.  For the purposes of this section, the term "supervisory public employee" means anyone with supervisory status, managerial status, confidential status, or any other status that would be a conflict of interest with the purpose of sections 105.570 to 105.595.

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(L. 2018 H.B. 1413)

*Revisor's Note:  On June 1, 2021, this section was declared unconstitutional in Missouri National Education Association v. Missouri Department of Labor and Industrial Relations, 623 S.W.3d 585 (Mo.banc).

(2021)  House Bill 1413 enacting section in 2018 held invalid as violation of equal protection clause of Article I, Section 2 of state constitution; section as enacted 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 2 cases (1 in the last 5 years), 2019–2021 · leading case: Missouri Nat'l Educ. Ass'n v. Missouri Dep't of Labor & Indus. Relations, 623 S.W.3d 585 (Mo. 2021).
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Missouri Nat'l Educ. Ass'n v. Missouri Dep't of Labor & Indus. Relations, 623 S.W.3d 585 (Mo. 2021). · cites it 2× “Section 105.570. In addition, HB 1413 transforms the manner in which a labor organization is selected and retained.”
Mucci v. St. Francois Cnty. Ambulance Dist., No. 4:19-cv-01868, 2019 WL 6170721 (E.D. Mo. Nov. 20, 2019). · cites it 2× “any public body or representative of a public body has violated or is about to violate any of the provisions of sections 105.570 to 105.590, . . . any citizen of the state of Missouri may bring a civil action for such relief, including injunctive relief, as may be appropriate.”
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