Board of Trustees of the University of Maine System v. Associated Colt Staff

Maine state law required public employers to bargain and negotiate in good faith. As part of this obligation, employers were also required to maintain the status quo inherent in a collective-bargaining agreement after its expiration and before a new agreement was reached. The Associated Colt Staff of the University of Maine System (the union) (plaintiff) represented employees of the University of Maine System (the university) (defendant). The parties had a collective-bargaining agreement in place for three years, which contained across-the-board wage increases for each year of the contract. On the anniversary of the agreement, employees would advance to the next tier of salary and receive a wage increase. Upon expiration of the agreement, the university adhered to the last wage schedule and ended the practice of annual wage increases. The union filed a prohibited-practice complaint with the Maine Labor Relations Board (the board), which ruled that the university had violated state law because its decision to discontinue the wage increases constituted a unilateral change in the conditions of employment. In its decision, the board adopted the dynamic status quo rule, whereby wage increases were incorporated into the status quo that must be maintained by the parties. The university filed a petition for review of final agency action with the superior court, which vacated the board’s decision. The union and board appealed.