The Public Safety Employer-Employee
Cooperation Act
Jon O. Shimabukuro
Legislative Attorney
Gerald Mayer
Analyst in Labor Policy
August 13, 2009
Congressional Research Service
7-5700
www.crs.gov
R40738
CRS Report for Congress
P
repared for Members and Committees of Congress

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The Public Safety Employer-Employee Cooperation Act

Summary
Since 1995, legislation that would guarantee collective bargaining rights for state and local public
safety officers has been introduced in Congress. The Public Safety Employer-Employee
Cooperation Act (PSEECA), introduced in the 111th Congress as H.R. 413 by Representative Dale
E. Kildee and S. 1611 by Senator Judd Gregg, would recognize such rights by requiring
compliance with federal regulations and procedures if these rights are not provided under state
law. Supporters of the measure maintain that strong partnerships between public safety officers
and the cities and states they serve are not only vital to public safety, but are built on bargaining
relationships. This report reviews the PSEECA and discusses the possible impact of the
legislation. The report also identifies existing state laws that recognize collective bargaining
rights for public safety employees, and considers the constitutional concerns raised by the
measure.


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The Public Safety Employer-Employee Cooperation Act

Contents
The Public Safety Employer-Employee Cooperation Act and the Commerce Clause.................... 2
Possible Impact of the Public Safety Employer-Employee Cooperation Act ................................. 5

Tables
Table 1. State Public Sector Collective Bargaining Laws ............................................................. 7

Contacts
Author Contact Information ...................................................................................................... 10

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The Public Safety Employer-Employee Cooperation Act

ince 1995, legislation that would guarantee collective bargaining rights for state and local
public safety officers has been introduced in Congress.1 The Public Safety Employer-
S Employee Cooperation Act (PSEECA), introduced in the 111th Congress as H.R. 413 by
Representative Dale E. Kildee and S. 1611 by Senator Judd Gregg, would recognize such rights
by requiring compliance with federal regulations and procedures if these rights are not provided
under state law. Supporters of the measure maintain that strong partnerships between public
safety officers and the cities and states they serve are not only vital to public safety, but are built
on bargaining relationships.2 This report reviews the PSEECA and discusses the possible impact
of the legislation. The report also identifies existing state laws that recognize collective
bargaining rights for public safety employees, and considers the constitutional concerns raised by
the measure.
Under the PSEECA, the Federal Labor Relations Authority (FLRA) would be required to
determine whether a state Asubstantially provides@ for specified labor-management rights within
180 days of the measure=s enactment.3 If the FLRA determines that a state does not substantially
provide for such rights, the state would be subject to regulations and procedures prescribed by the
FLRA. The FLRA=s regulations and procedures would be consistent with the labor-management
rights identified in the PSEECA. These rights include
• granting public safety officers the right to form and join a labor organization that
is, or seeks to be, recognized as the exclusive bargaining representative of such
employees;
• requiring public safety employers to recognize the employees= labor organization
(freely chosen by a majority of the employees), to agree to bargain with the labor
organization, and to commit any agreements to writing in a contract or
memorandum of understanding;
• providing for bargaining over hours, wages, and terms and conditions of
employment;
• making available an interest impasse resolution mechanism, such as fact-finding,
mediation, arbitration, or comparable procedures; and
• requiring the enforcement of all rights, responsibilities, and protections provided
by state law and any written contract or memorandum of understanding in state
courts.4

1 H.R. 413, 111th Cong. (2009); S. 1611, 111th Cong. (2009); H.R. 980, 110th Cong. (2007); S. 2123, 110th Cong.
(2007); H.R. 1249, 109th Cong. (2005); S. 513, 109th Cong. (2005); H.R. 814, 108th Cong. (2003); S. 606, 108th Cong.
(2003); H.R. 1475, 107th Cong. (2001); S. 952, 107th Cong. (2001); H.R. 1093, 106th Cong. (1999); S. 1016, 106th
Cong. (1999); H.R. 1173, 105th Cong. (1997); H.R. 1484, 104th Cong. (1995).
2 See, e.g., 153 Cong. Rec. S12382 (daily ed. Oct. 1, 2007) (statement of Sen. Kennedy) (AStudies show that
cooperation between public safety employers and employees improves the quality of services communities receive and
reduces worker fatalities.@).
3 H.R. 413, 111th Cong. ' 4(a)(1) (2009); S. 1611, 111th Cong. ' 4(a)(1) (2009). See H.R. 413, 111th Cong. § 3(10)
(2009) (defining the term “substantially provides” to mean “substantial compliance with the rights and responsibilities
described in section 4(b) [of the Public Safety Employer-Employee Cooperation Act].”); S. 1611, 111th Cong. ' 3(12)
(2009) (defining the term “substantially provides” to mean “compliance with each right and responsibility described in
[section 4(b) of the Public Safety Employer-Employee Cooperation Act].”).
4 H.R. 413, 111th Cong. ' 4(b) (2009); S. 1611, 111th Cong. ' 4(b) (2009).
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The Public Safety Employer-Employee Cooperation Act

The FLRA would have one year from the date of enactment of the PSEECA to issue regulations
that establish these rights for public safety officers in states that do not substantially provide
them.5 The new regulations would become applicable in noncomplying states either two years
after the date of enactment of the PSEECA or on the date of the end of the first regular session of
the state=s legislature that begins after the date of enactment of the PSEECA, whichever is later.6
The PSEECA defines the term Apublic safety officer@ to include law enforcement officers,
firefighters, and emergency medical services personnel.7 An Aemployer,@ for purposes of the act,
includes any state, political subdivision of a state, the District of Columbia, and any territory or
possession of the United States that employs public safety officers.8 A political subdivision of a
state that has a population of less than 5,000 or that employs fewer than 25 full time employees,
however, may be exempted from the act=s requirements.9
The Public Safety Employer-Employee Cooperation
Act and the Commerce Clause
The sponsors of the PSEECA appear to rely on the Commerce Clause of the U.S. Constitution for
the authority to enact the measure.10 Section 2(5) of the PSEECA states,
The potential absence of adequate cooperation between public safety employers and
employees has implications for the security of employees, impacts the upgrading of police
and fire services of local communities, the health and well-being of public safety officers,
and the morale of the fire and police departments, and can affect interstate and intrastate
commerce.
During the 110th Congress, the House Committee on Education and Labor further observed that
there is “little question that public safety employees= [sic] and their role in homeland security
affects interstate commerce ... The economic impact of terrorism and natural disasters is not
limited to the locality where these events occur. Rather, such events have regional and economic
impacts for which the federal government must be responsive.”11
Whether the Commerce Clause provides sufficient authority to support the PSEECA, however,
may not be entirely certain. Although the U.S. Supreme Court has found that the Fair Labor
Standards Act, a statute enacted pursuant to Congress=s authority under the Commerce Clause,

5 H.R. 413, 111th Cong. ' 5(a) (2009); S. 1611, 111th Cong. ' 5(a) (2009).
6 H.R. 413, 111th Cong. ' 4(c)(2) (2009); S. 1611, 111th Cong. ' 4(d)(1) (2009). S. 1611 further provides that a state
receiving a subsequent determination of failing to substantially provide for the specified labor-management rights will
become subject to the FLRA’s regulations on the last day of the first regular session of the state’s legislature that begins
after the date of the FLRA’s determination.
7 H.R. 413, 111th Cong. ' 3(2) (2009); S. 1611, 111th Cong. ' 3(10) (2009).
8 H.R. 413, 111th Cong. ' 3(8) (2009); S. 1611, 111th Cong. '§ 3(4), (11) (2009).
9 H.R. 413, 111th Cong. ' 8(b) (2009); S. 1611, 111th Cong. ' 8(a)(6) (2009).
10 U.S. Const. art. I, ' 8, cl. 3.
11 H.Rept. 110-232, at 18-19 (2007).
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can be applied to employees of a public mass-transit authority,12 more recent decisions involving
the Commerce Clause suggest that the regulation of labor-management relations for public safety
officers may not be sufficiently related to commerce and may be invalidated, if challenged.
In United States v. Lopez, a 1995 case involving the Gun-Free School Zones Act of 1990 and
Congress=s authority under the Commerce Clause, the Court identified three broad categories of
activity that Congress may regulate pursuant to its commerce power:
First, Congress may regulate the use of channels of interstate commerce ... Second, Congress
is empowered to regulate and protect the instrumentalities of interstate commerce, or persons
or things in interstate commerce, even though the threat may come only from intrastate
activities ... Finally, Congress= commerce authority includes the power to regulate those
activities having a substantial relation to interstate commerce ... i.e., those activities that
substantially affect interstate commerce.13
The Lopez Court concluded that the act, which prohibited any individual from possessing a
firearm at a place the individual knew or had reasonable cause to believe was a school zone,
exceeded Congress=s authority under the Commerce Clause because the possession of a gun in a
local school zone did not have a substantial effect on interstate commerce. The Court maintained
that upholding the act would require the Court to “pile inference upon inference in a manner that
would bid fair to convert congressional authority under the Commerce Clause to a general police
power of the sort retained by the States.”14
Similarly, in United States v. Morrison, a 2000 case involving Congress=s commerce power and a
section of the Violence Against Women Act, the Court found that Congress exceeded its authority
because gender-motivated crimes of violence occurring within a state have no substantial effect
on interstate commerce.15 The Court maintained that its cases upholding federal regulation of
intrastate activity all involve activity that reflects some form of economic endeavor.16 The Court
noted that the regulation and punishment of intrastate violence that is “not directed at the
instrumentalities, channels, or goods involved in interstate commerce has [sic] always been the
province of the States.”17
Most recently, in Gonzales v. Raich, the Court upheld the Controlled Substances Act (CSA) as a
valid exercise of Congress=s commerce authority.18 The CSA was challenged by two users of
medical marijuana that was locally grown and prescribed in accordance with California law. They
argued that Congress lacked the authority to prohibit the intrastate manufacture and possession of
marijuana for medical purposes.
Citing its decision in Wickard v. Filburn, a 1942 case that recognized Congress=s authority under
the Commerce Clause to regulate intrastate activities, the Court reiterated that even if an activity

12 See Garcia v. San Antonio Metropolitan Transit Authority, 469 U.S. 528 (1985).
13 514 U.S. 549, 558-59 (1995).
14 Id. at 567.
15 529 U.S. 598 (2000).
16 Id. at 611.
17 Id. at 618.
18 545 U.S. 125 (2005).
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is “local and ... may not be regarded as commerce, it may still, whatever its nature, be reached by
Congress if it exerts a substantial economic effect on interstate commerce.”19 The Court
maintained that the production of a commodity has a substantial effect on supply and demand in
the national market for that commodity, and observed that there was a likelihood that the high
demand in the interstate market would draw marijuana grown for home consumption into that
market.20
The Court distinguished Raich from Lopez and Morrison by noting that the CSA, unlike the Gun-
Free School Zones Act and the Violence Against Women Act, regulates activities that are
“quintessentially economic.”21 The Court indicated that “[t]he CSA is a statute that regulates the
production, distribution, and consumption of commodities for which there is an established, and
lucrative, interstate market. Prohibiting the interstate possession or manufacture of an article of
commerce is a rational (and commonly utilized) means of regulating commerce in that product.”22
While the PSEECA would not seem to regulate the channels or instrumentalities of interstate
commerce, it has been argued that it would regulate an activity that substantially affects interstate
commerce. By “improving the cohesiveness and effectiveness of public safety employers and
their employees,” it is believed that the PSEECA would minimize the costs associated with
terrorism and natural disasters.23 During the 110th Congress, the House Committee on Education
and Labor noted, “The economic impact of terrorism and natural disasters is not limited to the
locality where these events occur. Rather, such events have regional and national economic
impacts for which the federal government must be responsive.”24
Some maintain, however, that public safety employment is not an economic activity that may be
regulated pursuant to Congress=s commerce authority. In light of the Court=s decisions in Lopez,
Morrison, and Raich, it has been argued that police work, firefighting, and emergency medical
services are not economic enterprises or activities related to commercial transactions.25 Rather,
such duties are public services provided by states and localities to their citizens.26 Moreover, the
PSEECA would not be regulating the production, distribution, or consumption of a commodity
for which there is an interstate market by requiring collective bargaining rights for public safety
officers.27
While the PSEECA would seem to raise questions involving Congress=s authority under the
Commerce Clause, it does not appear to present concerns over the commandeering of state or

19 317 U.S. 111, 125 (1942).
20 Raich, 545 U.S. at 19.
21 Id. at 25.
22 Id. at 26.
23 H.Rept. 110-232, at 19 (2007).
24 Id.
25 See Kevin J. O=Brien, Federal Regulation of State Employment Under the Commerce Clause and ANational Defense@
Powers: Constitutional Issues Presented by the Public Safety Employer-Employee Cooperation Act, 49 B.C. L. Rev.
1175 (2008).
26 Id.
27 Id.
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local regulatory processes in violation of the Tenth Amendment.28 In New York v. United States, a
1992 case involving a federal requirement that gave states a choice between taking title to
radioactive waste or regulating in accordance with congressional directives, the Court indicated
that “Congress may not simply ‘commandee[r] the legislative processes of the States by directly
compelling them to enact and enforce a federal regulatory program.’”29
Unlike the provision at issue in New York, the PSEECA would not seem to direct states to
legislate collective bargaining for public safety officers. Instead, states would be given the option
of either enacting legislation that satisfies the federal standards or becoming subject to the
FLRA=s regulations. One might also contend that the measure does not appear to require state or
local governments to implement a federal regulatory program. Rather, a federal collective
bargaining scheme for public safety officers would be implemented by the FLRA only if a state
chose not to enact a program of its own.30
Possible Impact of the Public Safety Employer-
Employee Cooperation Act
The PSEECA has generated strong reactions from both the business and organized labor
communities, with the former generally opposing the measure and the latter supporting it. Critics
of the act emphasize the administrative and personnel costs that would likely be expended to
comply with the measure. Because of the difficulty in predicting how many workers may
organize or what terms and conditions would be negotiated, the cost of the measure for state and
local governments was not estimated by the Congressional Budget Office (CBO) when earlier
versions of the legislation were considered.
CBO did estimate, however, that the FLRA would need to spend an additional $3 million to
develop regulations, to determine whether states were in compliance with the law, and to respond
to judicial review of its determinations.31 Indeed, some have maintained that the PSEECA could
increase demands on the FLRA, either by stretching its resources or requiring new staff.32
Although subsequent costs are difficult to predict because states may respond differently and,

28 The Tenth Amendment of the U.S. Constitution states, AThe powers not delegated to the United States by the
Constitution, nor prohibited by it to the States, are reserved to the States respectively, or to the people.@
29 505 U.S. 144, 161 (1992) (quoting Hodel v. Virginia Surface Mining & Reclamation Assn., Inc., 452 U.S. 264, 288
(1981). See also Printz v. United States, 521 U.S. 898 (1997) (holding that Congress cannot circumvent New York=s
prohibition on compelling States to enact or enforce a federal regulatory program by conscripting State officers
directly).
30 See also H.Rept. 110-232, at 20 (“The Public Safety Employer-Employee Cooperation Act does not ‘commandeer’
state or local government by requiring that they enact or implement a federal regulatory program. The Act expressly
places the onus on states that do not yet provide full collective bargaining rights for public sector employees to either
provide the protections required in the Act, or to allow the FLRA to implement the Act.”).
31 Congressional Budget Office, S. 952, Public Safety Employer-Employee Cooperation Act of 2001, Sept. 24, 2001, at
2.
32 Testimony of David M. Smith, in Senate, Committee on Health, Education, Labor, and Pensions, Public Safety
Employer-Employee Cooperation Act of 1999, at 2.
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once given the right, public safety officers may or may not unionize, CBO estimated that the
FLRA would spend about $10 million annually to administer the act.33
Opponents of the PSEECA have also argued that the measure could raise the cost of public safety
because of potentially higher wages and benefits, as well as the cost of negotiating and
administering collective bargaining agreements.34
Supporters of the PSEECA contend that the measure would give many public safety workers the
right to organize and bargain collectively—rights that they may not currently have. The
arguments in support of the act are generally based on what proponents maintain are the benefits
of collective bargaining. For example, collective bargaining may improve the hours, pay, benefits,
and working conditions of public safety workers. Higher pay and better working conditions may
reduce turnover. Arguably, lower turnover could reduce the cost of hiring and training new
workers.
Supporters also argue that the PSEECA would give workers a “voice” in the workplace. They
maintain that unions provide workers an additional way to communicate with management.
Instead of expressing their dissatisfaction by quitting, workers can use formal procedures to
resolve issues relating to working conditions or other matters.35 Thus, according to supporters, the
PSEECA would give labor and management a way to work together to resolve differences.
Therefore, supporters further maintain that, by improving labor-management relations, the
measure would improve public safety.36

33 Congressional Budget Office, supra note 31 at 2.
34 Public Service Research Council, H.R. 814/S. 606, “The Public Safety Employer-Employee Cooperation Act,” May
2003, available at http://downloads.heartland.org/12523.pdf.
35 Richard B. Freeman and James L. Medoff, “The Two Faces of Unionism,” Public Interest, no. 57, Fall 1979, at 70-
73; Richard B. Freeman, “The Exit-Voice Tradeoff in the Labor Market: Unionism, Job Tenure, Quits, and
Separations,” Quarterly Journal of Economics, vol. 94, Jun. 1980, at 644-45.
36 Public Safety Employer-Employee Cooperation Act of 1999: Hearing Before the S. Comm. on Health, Educ., Lab.,
and Pensions, 106th Cong. 6-9 (2000) (statement of Frederick H. Nesbitt, Director of Governmental Affairs, Int’l Ass’n
of Firefighters); Id. at 16-18 (statement of Sen. Kennedy, Member, Sen. Comm. on Health, Educ., Lab., and Pensions).
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Table 1. State Public Sector Collective Bargaining Laws
State Citation
Alabama
Ala. Code § 11-43-143(b): Provides state and municipal firefighters with the right to
join a union and have proposals related to salaries and other conditions of
employment presented by such union. Public officials cannot, however, be
compelled to negotiate toward a labor contract. See Nichols v. Bolding, 277 So.2d
868 (Ala. 1973).
No similar statute with regard to other public safety officers.
Alaska
Alaska Stat. § 23.40.070: Recognizes col ective bargaining rights for al public
employees.
Arizona
Ariz. Rev. Stat. § 23-1411: Provides public safety officers with the right to join a
union. Employee wage negotiations, however, cannot be compel ed.
Arkansas
No public sector col ective bargaining laws.
California
Cal. Gov’t Code § 3502: Recognizes col ective bargaining rights for municipal public
employees.
Cal. Gov’t Code § 3515: Recognizes col ective bargaining rights for state public
employees.
Colorado
No public sector col ective bargaining laws.
Connecticut
Conn. Gen. Stat. § 5-271: Recognizes col ective bargaining rights for state public
employees.
Conn. Gen. Stat. § 7-468: Recognizes col ective bargaining rights for municipal
public employees.
Delaware
Del. Code Ann. tit. 19, § 1303: Recognizes col ective bargaining rights for al public
employees.
Del. Code Ann. tit. 19, § 1603: Recognizes col ective bargaining rights for police
officers and firefighters.
District of Columbia
D.C. Code § 1-617.06: Recognizes col ective bargaining rights for al public
employees.
Florida
Fla. Stat. § 447.301: Recognizes col ective bargaining rights for al public employees.
Georgia
Ga. Code Ann. § 25-5-4: Recognizes collective bargaining rights for local firefighters
if a municipality of 20,000 or more authorizes such rights by local ordinance.
No similar statute with regard to other public safety officers.
Hawaii
Haw. Rev. Stat. § 89-3: Recognizes collective bargaining rights for all public
employees.
Idaho
Idaho Code Ann. § 44-1802: Recognizes col ective bargaining rights for municipal
firefighters.
No similar statute with regard to other public safety officers.
Illinois
5 Ill. Comp. Stat. 315/6: Recognizes collective bargaining rights for all public
employees.
Indiana
No collective bargaining laws for public safety officers.
Iowa
Iowa Code § 20.8: Recognizes collective bargaining rights for all public employees.
Kansas
Kan. Stat. Ann. § 75-4324: Recognizes col ective bargaining rights for state public
employees.
Kan. Stat. Ann. § 75-4321(c): The governing body of any municipal employer may
recognize collective bargaining rights for its employees by a majority vote of its
members.
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Kentucky
Ky. Rev. Stat. Ann. § 67A.6902: Recognizes col ective bargaining rights for police
officers and firefighters employed by an urban-county government.
Ky. Rev. Stat. Ann. § 67C.402: Recognizes col ective bargaining rights for police
officers employed by a consolidated municipal government.
Ky. Rev. Stat. Ann. § 345.030: Recognizes col ective bargaining rights for municipal
firefighters in cities with more than 300,000 residents.
Ky. Rev. Stat. Ann. § 74.470: Recognizes col ective bargaining rights for municipal
police officers in counties with more than 300,000 residents.
Louisiana
No public sector col ective bargaining laws.
Maine
Me. Rev. Stat. Ann. tit. 26, § 963: Recognizes col ective bargaining rights for
municipal public employees.
Me. Rev. Stat. Ann. tit. 26, § 979-B: Recognizes col ective bargaining rights for state
public employees.
Maryland
Md. Ann. Code art. 28, § 5-114.1: Recognizes col ective bargaining rights for
Maryland-National Capital Park and Planning Commission police officers.
No similar statute with regard to other public safety officers.
Massachusetts
Mass. Gen. Laws ch. 150E, § 2: Recognizes col ective bargaining rights for al public
employees.
Michigan
Mich. Comp. Laws § 423.209: Recognizes col ective bargaining rights for al public
employees.
Minnesota
Minn. Stat. § 179A.06: Recognizes col ective bargaining rights for al public
employees.
Mississippi
No public sector col ective bargaining laws.
Missouri
Mo. Rev. Stat. §§ 105.510, 105.520: Provides public employees, except police,
deputy sheriffs, Missouri state highway patrolmen, and other specified individuals,
with the right to join a union and have proposals related to salaries and other
conditions of employment presented by such union. Public bodies are required to
discuss such proposals, but cannot be compelled to agree to them. See Null v. City
of Grandview, 669 S.W.2d 78 (Mo. App. W.D. 1984).
Montana
Mont. Code Ann. § 39-31-201: Recognizes col ective bargaining rights for al public
employees.
Nebraska
Neb. Rev. Stat. § 48-837: Recognizes col ective bargaining rights for al public
employees. See also Neb. Rev. Stat. § 81-1370 (recognizing col ective bargaining
rights for state public employees).
Nevada
Nev. Rev. Stat. § 288.140: Recognizes col ective bargaining rights for local public
employees.
New Hampshire
N.H. Rev. Stat. § 273-A:9: Recognizes col ective bargaining rights for al public
employees.
New Jersey
N.J. Stat. Ann. § 34:13A-5.3: Recognizes col ective bargaining rights for al public
employees.
New Mexico
N.M. Stat. § 10-7E-5: Recognizes col ective bargaining rights for al public
employees.
New York
N.Y. Civ. Serv. Law § 203: Recognizes collective bargaining rights for all public
employees.
North Carolina
N.C. Gen. Stat. § 95-98: Renders any agreement or contract between a public
employer and a union to be against public policy and void.
North Dakota
No public sector col ective bargaining laws.
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Ohio
Ohio Rev. Code Ann. § 4117.03: Recognizes col ective bargaining rights for al
public employees.
Oklahoma
Okla. Stat. tit. 11, § 51-103: Recognizes col ective bargaining rights for local
firefighters and police officers.
Oregon
Or. Rev. Stat. § 243.662: Recognizes col ective bargaining rights for al public
employees.
Pennsylvania
43 Pa. Cons. Stat. § 217.1: Recognizes col ective bargaining rights for state and
municipal police and firefighters.
43 Pa. Cons. Stat. § 1101.301: Recognizes col ective bargaining rights for al public
employees.
Rhode Island
R.I. Gen. Laws § 28-9.1-4: Recognizes collective bargaining rights for municipal
firefighters.
R.I. Gen. Laws § 28-9.2-4: Recognizes collective bargaining rights for municipal
police officers.
R.I. Gen. Laws § 28-9.5-4: Recognizes collective bargaining rights for state police
officers.
R.I. Gen. Laws § 36-11-1: Recognizes col ective bargaining rights for state public
employees, including members of the department of state police below the rank of
lieutenant.
South Carolina
No public sector col ective bargaining laws.
South Dakota
S.D. Codified Laws § 3-18-2: Recognizes col ective bargaining rights for al public
employees.
Tennessee
Tenn. Code Ann. § 49-5-603: Recognizes col ective bargaining rights for only
licensed employees of any local board of education.
Texas
Tex. Loc. Gov’t Code Ann. § 174.023: Collective bargaining rights for municipal
firefighters and police officers are available upon adoption of the Fire and Police
Employee Relations Act by majority vote in an election.
Utah
Utah Code Ann. § 34-20a-3: Recognizes col ective bargaining rights for municipal
firefighters.
Vermont
Vt. Stat. Ann. tit. 3, § 903: Recognizes col ective bargaining rights for state public
employees.
Vt. Stat. Ann. tit. 22, § 1721: Recognizes col ective bargaining rights for municipal
public employees.
Virginia
Va. Code Ann. § 40.1-57.2: Prohibits state and municipal employers from
recognizing any union as a bargaining agent for any public employees, and prohibits
the execution of a collective bargaining agreement with any such union.
Washington
Wash. Rev. Code § 41.56.040: Recognizes col ective bargaining rights for al public
employees.
West Virginia
No public sector col ective bargaining laws.
Wisconsin
Wis. Stat. § 111.70: Recognizes col ective bargaining rights for municipal public
employees.
Wis. Stat. § 111.82: Recognizes col ective bargaining rights for state public
employees.
Wyoming
Wyo. Stat. Ann. § 27-10-102: Recognizes col ective bargaining rights for municipal
firefighters.
Note: This table should not be interpreted as providing a determination of whether a state substantially
provides the rights prescribed by the Public Safety Employer-Employee Cooperation Act. The table simply
identifies whether a state’s public safety officers have the right to engage in collective bargaining.
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Author Contact Information

Jon O. Shimabukuro
Gerald Mayer
Legislative Attorney
Analyst in Labor Policy
jshimabukuro@crs.loc.gov, 7-7990
gmayer@crs.loc.gov, 7-7815




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