International Union of Operation Engineers Local 49 v. City of Minneapolis

Minnesota’s Public Employee Labor Relations Act (the act) imposed a duty on public employers to meet and confer in good faith. The city of Minneapolis (the city) (defendant) created the Department of Public Works (the department) to oversee construction projects. The department administered a civil-service examination for the position of foreman of equipment repair, which consisted of separate oral and written examinations. The city also evaluated applicants on the basis of an efficiency rating and a seniority rating. Several complaints were made after the examination. The International Union of Operation Engineers Local 49 (the union) (plaintiff) appealed to the Minneapolis Civil Service Commission (the commission), raising questions about the examination. The union alleged that some of the answers were incorrect and that many applicants had been reviewed by supervisors they had spent little to no time working with. The union appeared at a meeting of the commission and requested copies of all exam questions and answers, a list of the supervisors who had rated applicants, and information on when, where, and for how long supervisors had worked with applicants. At a meeting, the commission acknowledged problems with the examination and agreed to provide the union with copies of 11 examination questions. The commission also identified the supervisors who rated applicants. At a subsequent meeting, the commission refused to provide the remaining questions and answers or the other information requested. The union sought a writ of mandamus requiring the city to supply the requested information. The union made promises that it would not disclose the exam questions and answers. The district court granted the union’s request. The city appealed.