Master Builders of Iowa, Inc. v. Polk County

653 N.W.2d 382 (Iowa 2002) ; Clearinghouse Number: 55038

Description

Iowa Supreme Court Upholds Legality of Project Labor Agreement for Public Works Project

Abstract

The Iowa Supreme Court rejected a challenge by builder and contractor associations to a project labor agreement that county board of supervisors adopted to govern construction of a large-scale public works project. The agreement set the terms of labor relations for the contractor’s work on the project. Plaintiffs claimed that the agreement violated the state’s right-to-work and competitive bidding laws, was preempted by the National Labor Relations Act and Employee Retirement Income Security Act, and violated various constitutional rights. The court found that the agreement did not violate the right-to-work act because the agreement did not require employees to join a union; no evidence showed that the alleged “union hiring hall” had or would discriminate against nonunion members; and the agreement prohibited discrimination based on union membership. The state’s competitive bidding statute, which called for the award of a public improvements contract to the lowest responsible bidder, did not forbid the agreement, the court held, because the law gave board discretion to define “responsible bidder” as one who would work under the conditions of the agreement. The federal statutes did not preempt the agreement because, when board adopted the agreement, board acted in a proprietary, not a regulatory mode. Board’s public meetings before the agreement’s adoption and access to the courts afforded plaintiffs the notice and opportunity to be heard that due process required, the court held. Since the agreement was rationally related to a legitimate government interest and plaintiffs presented no evidence of discrimination based on union status, the agreement did not violate the equal protection guarantee. Disagreeing with plaintiffs’ claim that their right to free association was violated, the court held that the agreement did not force nonunion contractors to affiliate with union contractors or coerce prounion expression.

Additional Information

Attorney Information
Docket Date
2002-11-14 00:00:00+00:00

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