Missouri National Education Ass'n v. Missouri Department of Labor & Industrial Relations
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The Supreme Court affirmed the judgment of the circuit court finding the challenged provisions of House Bill No. 1413 violated multiple provisions of the Missouri Constitution and permanently enjoining its operation and enforcement, holding that HB 1413 is void in its entirety.
HB 1413, which was enacted in 2018, significantly altered many aspects of public labor relations in the state. The circuit court found (1) the exemption of public safety labor organizations in Mo. Rev. Stat. 105.503.2(1) violates public employees' right to bargain collectively through representatives of their own choosing, in violation of article I, section 29; and (2) the exemption of public safety labor organizations violated Mo. Const. art. I, 29. The Supreme Court affirmed, holding (1) the circuit court did not err in finding that the exemption of public safety labor organizations violates multiple provisions of the Missouri Constitution and in permanently enjoining Defendants from administering or enforcing any provision of HB 1413; and (2) the operation of the subject exemption forces the Court to declare HB 1413 void in its entirety rather than sever the offending provision.
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