LABOR DISPUTE, Financing, Special strike fund dues, Meaningful connection, Significant amounts, Proximate relation, Foreseeability of unemployment
CITE AS: Baker v General Motors Corp, 420 Mich 563 (1984); Aff'd 478 US 621 (1986).
Appeal pending: No
Claimant: A. G. Baker, et al
Employer: General Motor Corporation
Docket No: B69 3117 40569
SUPREME COURT HOLDING: A meaningful connection between financing a labor dispute and unemployment exists where the worker engages in financing in significant amounts and at times proximately related to the dispute which caused the worker's unemployment.
FACTS: The relevant national and local agreements expired in September, 1967. The claimants paid special increased strike fund dues in the following two months. Workers at several functionally integrated plants struck the employer in January, 1968 and drew strike pay. The claimants became unemployed when the strikers caused a shut down of operations at their locations.
DECISION: Plaintiffs are disqualified because they financed a labor dispute meaningfully connected with their unemployment.
RATIONALE: Plaintiffs paid emergency dues "for the purpose of supporting labor disputes. It was foreseeable that the dues would be used to support local strikes. Because the operation of General Motors is comprised of a series of interrelated production units ... it was foreseeable that a strike against one plant would result in layoffs at plants not involved in the dispute ... The amount of emergency dues when considered in the aggregate, in terms of the plaintiffs contributions and in terms of the effect on the strikers, was significant and demonstrates a meaningful connection with the dispute that caused the unemployment." Payment of the emergency dues immediately preceded the dispute that caused the unemployment, the time lag being minimal when considered in the light of the method employed.
After remand, the decision of the Board is affirmed by an equally divided court.
NOTE: The U.S. Supreme Court held the "financing" disqualification in the Michigan statute as construed by the state Supreme Court is not preempted by federal law. While federal law protects the employees' right to authorize a strike, it does not prohibit a state from deciding whether or not to compensate employees who thereby cause their own unemployment.
3, 6, 15, d5 & 14:D