This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The University of New Mexico (UNM) adopted a labor-management relations policy in 1970, revised in 1979 and 1980, which excluded certain categories of employees, such as faculty, professional, and technical staff, from collective bargaining. In 1992, the New Mexico Legislature enacted the Public Employee Bargaining Act (PEBA), which guaranteed public employees the right to organize and bargain collectively, excluding only management, supervisory, and confidential employees. Disputes arose when the New Mexico Federation of Teachers (NMFT) and the American Association of University Professors (AAUP) challenged UNM's policy for excluding certain employees from collective bargaining (paras 2-8).
Procedural History
- Public Employee Labor Relations Board (PELRB), March 6, 1996: The PELRB hearing officer invalidated portions of UNM's labor policy, finding it violated PEBA by excluding certain employees from collective bargaining. The officer also rejected UNM's argument that its policy was exempt under PEBA's grandfather clause and found no conflict with the Regents' constitutional autonomy (paras 8-10).
- PELRB, June 25, 1996: The PELRB adopted the hearing officer's conclusions, affirming that UNM's policy violated PEBA and rejecting the constitutional argument. However, it found that the AAUP's petition for recognition as a bargaining agent did not conform to PEBA requirements (para 12).
- District Court, April 1, 1997: The district court affirmed the PELRB's decision, upholding the invalidation of UNM's policy and rejecting the constitutional challenge (para 13).
Parties' Submissions
- Appellant (UNM): Argued that its labor policy was exempt under PEBA's grandfather clause because it predated the Act and had successfully negotiated collective bargaining agreements. UNM also contended that applying PEBA to its policy infringed on the Regents' constitutional autonomy to govern the university (paras 1, 8-9, 13).
- Respondents (NMFT and AAUP): Asserted that UNM's policy violated PEBA by excluding employees who were entitled to collective bargaining rights under the Act. They argued that PEBA did not conflict with the Regents' constitutional authority (paras 5-6, 9).
Legal Issues
- Was UNM's labor policy exempt from PEBA under the Act's grandfather clause?
- Did PEBA conflict with the constitutional autonomy of the UNM Board of Regents?
Disposition
- The Supreme Court of New Mexico affirmed the district court's decision, holding that UNM's labor policy was not exempt under PEBA's grandfather clause and that PEBA did not infringe on the Regents' constitutional autonomy (para 15).
Reasons
Per Franchini CJ (Baca, Minzner, Serna, and McKinnon JJ. concurring):
Grandfather Clause: The court held that UNM's policy did not qualify for grandfather status under PEBA because it excluded categories of employees who were entitled to collective bargaining rights under the Act. The court emphasized that PEBA's purpose was to guarantee collective bargaining rights to all public employees, except those explicitly excluded, and that UNM's policy failed to meet this standard (paras 34-49).
Constitutional Autonomy: The court rejected UNM's argument that PEBA infringed on the Regents' constitutional authority to govern the university. It found that PEBA only required UNM to bargain in good faith and did not mandate specific outcomes or interfere with the Regents' control over educational policy. The court noted that any potential conflicts could be addressed on a case-by-case basis by the PELRB (paras 50-60).
Public Policy: The court underscored that PEBA was enacted to promote harmonious labor relations and protect the public interest, and that UNM's policy undermined these objectives by excluding certain employees from collective bargaining (paras 47-49).