Independence-National Education Association v. Independence School District

Article I, § 29 of Missouri’s constitution guaranteed all employees the right to collectively bargain through representatives of their own choosing. Article I, § 29 did not explicitly define employees or limit the definition of employees to those in the private sector. A separate public-sector labor law protected this right for public-sector employees, but it explicitly excluded teachers. It was common practice for three different public-employee unions (the unions) (plaintiffs) to meet with the school board (the board), which represented the school district (defendant), in order to discuss and agree on proposals for the employment relationship, including details such as working conditions and salaries. The agreements were outlined in official memorandums of understanding, as required by public-sector labor law. Teachers also engaged in this practice with the district. In 2002 the board had official memorandums in effect with all of the unions. The board also had a discussion procedure in place with the teachers’ union. Despite this, the board unilaterally adopted a collaborative team policy (the policy) without meeting with the unions. The policy changed terms of employment relating to grievances, payroll, employee discipline, and dismissal. The policy also rescinded the discussion procedure. The unions sued, contending that the board’s refusal to engage in collective bargaining violated the Missouri constitution. The unions also contended that the board could not unilaterally rescind the agreements in place. The trial court ruled against the unions, who filed an appeal to the Missouri Supreme Court.