Parks v. Employment Security Commission

Boyle, J.

(concurring in part and dissenting in part). I concur in Justice Riley’s finding that Lindquist was disqualified from the receipt of unemployment benefits under § 29(l)(a). I would find that Dr. Parks’ refusal to pay union dues resulted in termination pursuant to the collective bargaining agreement. Because Mr. Dolce’s retirement was for reasons beyond his control, I agree with Justice Brickley’s result.

I further agree with Justice Riley that it is inappropriate in these cases to engage in a strained construction of the "work connected” requirement for disqualification on the basis of misconduct. Thus, I concur with Justice Brickley’s result in Parks, but not with his analysis in that case.

Cavanagh, J. (concurring in part and dissenting in part).

LINDQUIST

I concur with Justice Riley’s application of §29(l)(a) of the Michigan Employment Security Act to plaintiff Lindquist’s violation of the Saginaw City residency requirement.

parks .

I concur with Justice Brickley’s decision in *267Parks; however, I would find that Parks, like Lindquist, was disqualified under § 29(l)(a) of the Michigan Employment Security Act. Parks’ failure to pay agency fees constituted a voluntary leaving of her work.

It should be noted that the Supreme Court remand in Abood v Detroit Bd of Ed, 431 US 209; 97 S Ct 1782; 52 L Ed 2d 261 (1977), clearly encouraged Mrs. Parks to use the internal procedure established by the union for determining her pro-rata share of the agency fees.1

On remand to the circuit court, the trial judge ordered a stay in the proceedings to allow exhaus*268tion of the internal union remedies.2 Apparently Mrs. Parks refused to participate in the union procedure, and the circuit court dismissed her case on that basis. She did not appeal the circuit court’s dismissal of her case for lack of standing. The appeal of her firing under the teacher tenure act to the Court of Appeals did not raise the constitutional issue discussed in Chicago Teachers Union v Hudson, 475 US 292; 106 S Ct 1066; 89 L Ed 2d 232 (1986). Her motion for reconsideration was properly denied by the Court of Appeals as the constitutional issue had not been properly preserved.

DOLCE

Plaintiff Dolce was required to retire pursuant to a collective bargaining agreement between the employees and the employer. The retirement age was sixty-five years unless the employee wished to work an additional three years. Dolce chose to work until age sixty-eight.

The lead opinion for reversal finds that Dolce is entitled to unemployment benefits as he did not voluntarily leave his work. It would hold that the collective bargaining process is too remote from the individual to allow any legislative presumption that an employee is bound by the agreement. In effect, an employee is considered not to have consented to the collective bargaining agreement.

The case on which the lead opinion relies, Campbell Soup Co v Employment Security Bd of Review, 13 NJ 431; 100 A2d 287 (1953), was rejected by the Court of Appeals in Applegate v Palladium Publishing Co, 95 Mich App 299; 290 NW2d 128 (1980), lv den 409 Mich 904 (1980). In Applegate, the Court of Appeals agreed with the Minnesota Supreme Court that, by being a member of the *269union, an employee has ratified or joined in union decisions and is bound by the decisions. Bergseth v Zinsmaster Baking Co, 252 Minn 63; 89 NW2d 172 (1958).3 Thus, an employee like Dolce has given his consent, either express or implied, to the terms of the collective bargaining agreement including the retirement provisions.

The lead opinion looks to section two of the Michigan Employment Security Act to establish that unemployment benefits are to be used "for the benefit of persons unemployed through no fault of their own.” No one has alleged any fault or misconduct on Dolce’s part. Section two also provides that unemployment benefits serve as protection against the "crushing force” of unemployment and "th[e] hazard[s] of our economic life.” The act was also designed to encourage employers to establish "stable employment.” MCL 421.2; MSA 17.502.

The facts establish that Ford Motor Company provided Dolce with stable employment for over thirteen years. Dolce’s retirement was not the result of a layoff or plant closing or any precipitous economic condition. A negotiated retirement is a contractual benefit to an employee designed to prevent unexpected economic loss. Indeed, the provision of the retirement plan in the present case allowing an employee three additional years of work seems most equitable.

Justice Brickley upholds plaintiff Parks’ disqualification from unemployment benefits on the basis that the union properly exercised its contract rights in requesting that the employer terminate Parks for her refusal to pay agency fees as the forced collection of these fees had been held consti*270tutional in Abood, supra.4 If this same rationale is applied to Dolce, it is clear that the collective bargaining contract may be properly invoked to mandate retirement as bona fide retirement plans are a recognized exception to the constitutional prohibition against age discrimination. Michigan Civil Rights Act.5

I would find Dolce disqualified for unemployment benefits under § 29(l)(a) of the Michigan Employment Security Act._

In view of the newly adopted Union internal remedy, it may be appropriate under Michigan law, even if not strictly required by any doctrine of exhaustion of remedies, to defer further judicial proceedings pending the voluntary utilization by the parties of that internal remedy as a possible means of settling the dispute.45

We express no view as to the constitutional sufficiency of the internal remedy described by the appellees. If the appellants initially resort to that remedy and ultimately conclude that it is constitutionally deficient in some respect, they would of course be entitled to judicial consideration of the adequacy of the remedy. [431 US 242.]

Detroit Bd of Ed v Parks, 98 Mich App 22, 46, n 24; 296 NW2d 815 (1980).

MESC v Vulcan Forging Co, 375 Mich 374; 134 NW2d 749 (1965), can be distinguished from the present case. It involved a forced, unpaid vacation for low seniority employees due to a plant shutdown.

See discussion of Parks.

MCL 37.2202; MSA 3.548(202):

(1) An employer shall not:

(a) Pail or refuse to hire, or recruit, or discharge, or otherwise discriminate against an individual with respect to employment, compensation, or a term, condition, or privilege of employment, because of religion, race, color, national origin, age, sex, height, weight, or marital status.

(b) Limit, segregate, or classify an employee or applicant for employment in a way which deprives or tends to deprive the employee or applicant of an employment opportunity, or otherwise adversely affects the status of an employee or applicant because of religion, race, color, national origin, age, sex, height, weight, or marital status.

(c) Segregate, classify, or otherwise discriminate against a person on the basis of sex with respect to a term, condition, or privilege of employment, including a benefit plan or system.

(2) This section shall not be construed to prohibit the establishment or implementation of a bona fide retirement policy or system which is not a subterfuge to evade the purposes of this section.

(3) This section shall not apply to the employment of an individual by his or her parent, spouse, or child.