Sault Ste Marie Area Public Schools v. Michigan Education Ass'n

The Michigan Education Association (mea) appeals as of right from a decision and order of the Michigan Employment Relations Commission (merc) determining that substitute teachers employed by the Sault Ste. Marie Public Schools could not be included in the same collective bargaining unit as regular, full-time teachers. We affirm.

From the 1960s through the middle of the 1980s, the merc adopted a so-called "per diem policy” concerning the inclusion of substitute teachers in a bargaining unit consisting of regular, full-time teachers. Under that policy, per diem substitute teachers were deemed to…