AFSCME v. The Illinois Labor Relations Board

Illinois Appellate Court
Civil Court
Unions
Citation
Case Number: 
2017 IL App (1st) 160960
Decision Date: 
Friday, May 26, 2017
District: 
1st Dist.
Division/County: 
ILRB, 6th Div.
Holding: 
Reversed (No. 1-16-0960); and vacated (No.1-16-2034)
Justice: 
ROCHFORD

Union represented county department of corrections sergeants, and filed a unit clarification petition to include in bargaining unit 8 employees of county and sheriff assigned to electronic monitoring (EM) unit at county jail. Illinois Labor Relations Board (ILRB) issued unit clarification certification order including EM sergeants in bargaining unit. Parties must comply with express provisions of Sections 9(a)(2) and 9(a-6) of Illinois Public Labor Relations Act for reviewing union's certification. As ILRB's executive director lacked authority and thus, jurisdiction to revoke union's certification and reopen proceedings on union's unit clarification petition, the resulting order dismissing the unit clarification petition was void. (HOFFMAN and DELORT, concurring.)