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Iowa State Education Association v. State

Supreme Court of Iowa

May 17, 2019


          Appeal from the Iowa District Court for Polk County, Michael D. Huppert, Judge.

         Unions representing public school employees appeal summary judgment dismissing their constitutional challenges to 2017 amendments to the Public Employment Relations Act. AFFIRMED.

          Alice O'Brien and Lubna A. Alam of the National Education Association, Washington, D.C.; Becky S. Knutson of Davis, Brown, Koehn, Shors & Roberts, P.C., Des Moines; and Jeremiah A. Collins of Bredhoff & Kaiser P.L.L.C., Washington, D.C., for appellants.

          Matthew C. McDermott, Michael R. Reck, Kelsey J. Knowles, and Espnola F. Cartmill of Belin McCormick, P.C., Des Moines, for appellees.

          Jay M. Smith of Smith & McElwain Law Office, Sioux City, for amici curiae Iowa Federation of Labor, AFL-CIO; Communications Workers of America; and International Union of Operating Engineers, Local 234.

          Adam D. Zenor of Grefe & Sidney, P.L.C., Des Moines, and Frank D. Garrison of National Right to Work Legal Defense Foundation, Springfield, Virginia, for amicus curiae Kevin Rohne.


         This appeal, submitted with AFSCME Iowa Council 61 v. State, ___ N.W.2d___ (Iowa 2019), also filed today, presents constitutional challenges to the 2017 amendments to Iowa Code chapter 20, the Public Employment Relations Act (PERA). The amendments ended payroll deductions for union dues and narrowed the scope of mandatory collective bargaining topics for bargaining units comprised of less than thirty percent "public safety employees," defined to include most police officers and firefighters but not prison guards, campus police officers, and emergency medical technicians. The new classifications result in many public employees losing significant statutory bargaining rights compared to other public employees with arguably similar jobs. Two unions representing public school employees filed this action seeking injunctive and declaratory relief against the State of Iowa, the Iowa Public Employment Relations Board (PERB), and three PERB board members. The plaintiffs allege the 2017 amendments violate the equal protection clause of the Iowa Constitution. The district court granted the defendants' motion for summary judgment dismissing the action, and we retained the plaintiffs' appeal.

         Our role is to decide whether constitutional lines were crossed, not to sit as a superlegislature rethinking policy choices of the elected branches. We conclude the 2017 amendments withstand the constitutional challenges. The parties agree the equal protection claims are reviewed under the deferential rational basis test. As more fully explained in AFSCME Iowa Council 61, the legislature could reasonably conclude that the goal of keeping labor peace with unions comprised of at least thirty percent public safety employees, and the greater risks faced by police and firefighters, justified the classification. We hold the legislative classifications are not so overinclusive or underinclusive as to be unconstitutional under our court's rational basis test. For the reasons explained below, we also reject the plaintiffs' equal protection challenge to the prohibition on payroll deductions for union dues. Accordingly, we affirm the district court's summary judgment in favor of the defendants.

         I. Background Facts and Proceedings.

         In this case, we consider another challenge to House File 291 amending PERA, Iowa's collective bargaining statute, Iowa Code chapter 20. We discuss chapter 20 and House File 291's 2017 amendments in AFSCME Iowa Council 61, ___ N.W.2d at___, and do not repeat that discussion here.

         The plaintiffs in this case, the Iowa State Education Association (ISEA) and the Davenport Education Association (DEA), are unions representing public school employees. The ISEA represents more than 30, 000 members throughout the state, most of whom are public school teachers. The ISEA has 400 local associations that negotiate collective bargaining agreements with school districts in Iowa. The DEA represents the professional staff working for the Davenport Community School District. PERB has certified the DEA as the exclusive bargaining agent to represent those employees. The employees represented by the ISEA and the DEA are not "public safety employees" as defined in the 2017 amendments.

         In April 2017, the ISEA and the DEA filed this civil action for declaratory and injunctive relief, alleging House File 291 violated article I, section 6 of the Iowa Constitution by denying equal treatment to the unions and the employees they represent.[1] The defendants, the State of Iowa; PERB; PERB's chairperson, Mike Cormack; and PERB board members Jamie Van Fossen and Mary Gannon, filed an answer and affirmative defenses. The parties filed cross-motions for summary judgment.

         The district court concluded that House File 291 passed rational basis scrutiny without violating article I, section 6 of the Iowa Constitution and, therefore, granted summary judgment in favor of the defendants. As to the differentiation between public safety employees and all other public employees, the district court concluded that the legislature gave public safety employees greater bargaining rights because of the potential risk to public safety if these employees went on strike and because, if other public employees went on strike, it would fall on public safety employees to enforce the law in the ensuing labor unrest. Because the district court relied on the strike-avoidance rationale, the court did not consider the State's other proffered rationale that the differentiation was also rationally based on the unique safety issues public safety employees face requiring expansive bargaining rights on topics like health insurance. As to payroll deductions, the district court accepted the fiscal responsibility goal advanced by the State, reasoning that the legislature could conclude "that collective bargaining is expensive, disruptive and not in the best interest of citizens" and there was no constitutional requirement to continue payroll deductions for union dues merely because payroll deductions for other organizations were permitted.

         The ISEA and the DEA appealed, and we retained their appeal.

         II. Scope of Review.

         "We review summary judgment rulings for correction of errors at law." Baker v. City of Iowa City, 867 N.W.2d 44, 51 (Iowa 2015). "We view the entire record in the light most favorable to the nonmoving party, making every legitimate inference that the evidence in the record will support in favor of the nonmoving party." Bass v. J.C. Penney Co., 880 N.W.2d 751, 755 (Iowa 2016).

         We review constitutional claims de novo. State v. Groves, 742 N.W.2d 90, 92 (Iowa 2007). Our standard of review with regard to constitutional challenges to statutes is well established,

We review constitutional challenges to a statute de novo. In doing so, we must remember that statutes are cloaked with a presumption of constitutionality. The challenger bears a heavy burden, because it must prove the unconstitutionality beyond a reasonable doubt. Moreover, "the challenger must refute every reasonable basis upon which the statute could be found to be constitutional." Furthermore, if the statute is capable of being ...

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