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American Federation of State, County, and Municipal Employees Local 201 v. City of Muskegon

Michigan Supreme Court

120 N.W.2d 197 (1963)

Facts

The City of Muskegon (defendant) promulgated a rule banning police officers from affiliating with any labor union whose membership included persons outside the Muskegon police department. The rule was intended to preserve the ability of police officers to act as impartial neutralizers in controversies over the right of public assembly or association, neighborhood disputes, domestic difficulties, strikes, and issues between labor and management. Officers who were members of such unions were given 30 days to disassociate from the unions or face immediate dismissal. The American Federation of State, County, and Municipal Employees Local 201 (Local 201) (plaintiff) filed suit in the Muskegon County Circuit Court seeking injunctive relief on the grounds that the rule was ambiguous, was arbitrary and capricious, and deprived Local 201 and police officer-members of rights under the state and federal constitutions. The circuit court issued the injunction, and the city appealed.

Rule of Law

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Issue

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Holding and Reasoning (Carr, C.J.)

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