[Congressional Record Volume 172, Number 100 (Monday, June 15, 2026)]
[Extensions of Remarks]
[Pages E573-E576]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]




                       FASTER LABOR CONTRACTS ACT

                                 ______
                                 
speech of

                            HON. TIM WALBERG

                              of michigan

                    in the house of representatives

                         Tuesday, June 9, 2026

  Mr. WALBERG. Mr. Speaker, I include in the Record the following 
letters from Alex McDonald and Roger King, in opposition to H.R. 5408.

     Re Opposition to the Faster Labor Contracts Act--H.R. 5408

                                                     June 9, 2026.
     Hon. Tim Walberg,
     Chairman, House Committee on Education and Workforce, 
         Washington, DC.
       Dear Chairman Walberg: We are writing regarding H.R. 5408, 
     the Faster Labor Contracts Act (``FLCA''). The FLCA is a 
     deeply flawed piece of legislation that should not be 
     considered by this Congress--or any other. It aims to speed 
     up negotiations for first collective-bargaining agreements 
     between employers and workers. The bill's authors evidently 
     believe that those negotiations take too long. But while 
     negotiations are long, they are long for a reason: 
     negotiating a first contract is hard. It involves detailed 
     financial and operational tradeoffs, which the parties must 
     negotiate from ground zero. So it is no surprise that 
     contracts often take weeks, months, or years to finalize. 
     That ``delay'' is not a sign that the process is broken; it 
     is a sign that the process is working.
       Worse, the bill proposes to solve that problem with a 
     deeply flawed approach. It would funnel the parties through a 
     compressed bargaining schedule, terminating in compulsory and 
     binding arbitration. Parties would have only 90 days to 
     negotiate their own agreements, after which the bill's 
     processes would kick in. Those processes would be 
     exceptionally burdensome and expensive, requiring complex and 
     cost-heavy hearings to ``prove'' what a ``fair'' contract 
     would be. America's businesses cannot afford that burden, and 
     Congress should not force them to swallow it.
       If that weren't enough, the bill is likely 
     unconstitutional. It would raise serious questions under the 
     Due Process Clause, the Vesting Clauses, and the Appointments 
     Clause. It would also threaten to convert every collective-
     bargaining agreement imposed under its procedures into 
     ``state action,'' dragging constitutional doctrines into the 
     American workplace. These problems have not been considered, 
     much less vetted. The bill needs serious rework, and members 
     should not vote for it if they take seriously their oath to 
     uphold the Constitution.
       Yet despite these problems, some members are pushing the 
     legislation through with an unusual procedure--the discharge 
     petition. That procedure is inappropriate in most cases and 
     especially inappropriate here. This bill is deeply 
     problematic and needs the scrutiny of ordinary legislative 
     processes. It should not be rammed through with extraordinary 
     procedural maneuvers.
       We urge you and the other members of Congress to reject the 
     discharge petition and reject this bill.
       As you are aware, the House will be considering H.R. 5408 
     as a result of a discharge petition signed by certain Members 
     that requires the House to consider and schedule a vote on 
     this legislation without the benefit of Committee 
     deliberation. This discharge protocol and procedure is not 
     the preferred method to consider legislation. It precludes 
     meaningful input from all stakeholders who are potentially 
     impacted by the legislation in question. H.R. 5408 has not 
     had the benefit of any meaningful Member or staff analysis. 
     No hearings have been held on this legislation. No 
     opportunity has been provided for stakeholders to file 
     comments and submit questions regarding the legislation.
       More troubling, no technical analysis has been undertaken 
     regarding the legislation. And that analysis is badly needed, 
     as this legislation is technically defective in several 
     respects and is not in proper form to be considered by the 
     House of Representatives. No financial or cost analysis has 
     been undertaken. No Committee markup has occurred regarding 
     this legislation.
       This legislation should be referred back to the House 
     Education and Workforce Committee (``Committee'') to permit 
     Members and all stakeholders to consider counterproposals, 
     amendments, appropriate background research information, and 
     academic studies regarding the impact of this legislation. We 
     urge you and your colleagues to have H.R. 5408 returned to 
     the Committee.
       Proponents of H.R. 5408 assert that there is a significant 
     problem with the time period it takes parties to reach an 
     agreement on an initial collective bargaining agreement. They 
     allege that employers are largely responsible for delays, and 
     such delays in the negotiation process are designed to 
     undermine union representation. They further allege that such 
     delay strategies are often part of employers' plans to 
     decertify or remove a union. There is no reliable data to 
     support these arguments and allegations.
       First, it is very difficult to ascertain the start date of 
     collective bargaining in negotiations, especially for first 
     contracts, where the parties may not have any prior 
     relationship. Does the start date of negotiations begin when 
     one party sends another party a request for information and 
     documents?--a procedure often used by unions to prepare for 
     negotiations. Does the negotiation start date begin when the 
     parties start general discussions about the issues to be 
     discussed in negotiations? Does a preliminary discussion 
     regarding whether the parties should conclude non-economic 
     issues before moving to economic issues start the negotiation 
     process? Do mutually agreed upon delay periods in

[[Page E574]]

     negotiations--which often occur--count toward the average 
     time it takes for first contracts to be completed? When does 
     the negotiation period end? Does it end when a tentative 
     agreement is reached or when any tentative agreement is 
     ultimately ratified by bargaining unit members? What if a 
     tentative agreement is reached between a union and an 
     employer, but the bargaining unit rejects it? Does the 
     subsequent period after such a tentative agreement is 
     reached count toward the average negotiation period for 
     initial contracts?
       Further, how should legitimate litigation initiatives be 
     counted under the days it takes to negotiate an initial 
     contract? A union or an employer may have good faith reasons 
     to contest a decision of the National Labor Relations Board 
     (``NLRB'' or ``Board'') regarding the categories of employees 
     that the Board included or excluded from the bargaining unit. 
     Well-established federal labor law permits unions and 
     employers to appeal decisions through the federal court of 
     appeals--test of certification cases. Such appeal periods 
     can, at a minimum, take months if not over a year depending 
     on if a circuit-worthy appeal is filed. Additionally, what if 
     a union legitimately believes it needs certain information 
     from an employer before it can sufficiently bargain or 
     conclude bargaining? For example, information regarding the 
     cost of certain employer-provided health benefits and limits 
     of coverage of any employer policy could be information that 
     the union believes is necessary to make proposal in the 
     health insurance area. Should the period it takes the NLRB to 
     resolve any dispute of the scope of the information request 
     be included in calculating the time period to negotiate an 
     initial collective bargaining agreement? There are many other 
     examples that could be listed and should be analyzed and 
     considered in calculating the number of days that it takes 
     parties to negotiate labor contracts.
       Absent a comprehensive and thorough analysis of the details 
     of hundreds of initial collective bargaining negotiations 
     over an extended period of time, there can be no meaningful 
     or reliable data to support any conclusions about the average 
     time it takes parties to negotiate such agreements.
       Even if thoughtful or comprehensive studies could be 
     conducted to determine the average time it takes parties to 
     reach an initial collective bargaining agreement--which has 
     not been done to date--the results of any studies, in all 
     probability, would show it takes a substantial amount of time 
     to reach initial labor contract agreements. Such an analysis 
     may very well show that it takes in excess of over four 
     hundred days (400) on average to reach an agreement. Members 
     of Congress need to understand that this is a complex 
     process. Labor contracts often contain many articles and, in 
     some cases, are over one hundred (100) pages. These initial 
     agreements also often contain appendices, memoranda of 
     understanding, and ``side letters.'' These agreements, 
     especially from the union perspective, attempt to cover 
     virtually all of an employee's relationship with their 
     employers. The bottom line is that bargaining these contracts 
     takes time--considerable time.
       The importance of carefully and thoughtfully negotiating 
     first contracts and their terms cannot be emphasized enough. 
     Such negotiations are critical for employees, unions, and 
     employers. There are good reasons that it takes time to 
     negotiate initial collective bargaining agreements. The 
     parties are not just negotiating over wages. They are 
     constructing a comprehensive workplace contractual framework, 
     including work schedule details, health and retirement 
     benefits, paid time off and holidays, discipline standards, 
     grievance and arbitration procedures, and dozens of other 
     topics critical to employees and employers. These 
     negotiations can be time-consuming because the results of 
     such negotiations and the contents of an initial collective 
     bargaining agreement are critical for the union to continue 
     as a representative for employees and for the employer to 
     continue its business operations.
       Additionally, there are other reasons that may explain that 
     a significant amount of time is needed to negotiate initial 
     collective bargaining agreements. For example, either unions 
     or employers may exercise lawful, legitimate litigation 
     rights that must be resolved before and during negotiations. 
     Further, a union may have made a considerable number of 
     promises in its campaign prior to an election--a tactic that 
     is often used by unions and is lawful under the National 
     Labor Relations Act (``NLRA'' or ``Act''). It may take the 
     union a considerable period of time to try to convince an 
     employer of the merits of its proposals related to campaign 
     promises to bargaining unit members. Alternatively, it may 
     take considerable time in negotiations before a union and its 
     members conclude that an employer will not agree to such 
     proposals. The union may also attempt to obtain an agreement 
     on issues that fall into the category of ``permissive 
     subjects of bargaining'' under the NLRA. An example would be 
     a union proposal regarding the number of employees that an 
     employer would be required to hire to run its business, 
     including staffing on certain units or departments. An 
     employer may lawfully disagree with the unions proposal 
     regarding these permissible bargaining proposals. These types 
     of negotiations can be very time consuming.
       Initial collective bargaining agreements are also 
     singularly important to the parties because they carry much 
     greater weight than common law contracts. As explained in 
     more detail below (see discussion of the Supreme Court's Katz 
     no unilateral change doctrine), the terms included in a first 
     contract do not expire when the contract expires. In effect, 
     they are legally presumed to continue indefinitely, until or 
     unless they are expressly altered by mutual agreement of the 
     parties. This unusual characteristic of federal labor law 
     contracts gives their provisions a kind of initial inertia 
     that tends to carry them through many successful agreements 
     for literally decades.
       It is important for members of Congress to understand the 
     significance and complexity of initial collective bargaining 
     agreements before enacting any regulation or oversight. H.R. 
     5408, unfortunately, is an improper intrusion into the 
     collective bargaining process and, as further detailed below, 
     fails to recognize the complexity and time necessary to 
     negotiate an initial collective bargaining agreement.
       H.R. 5408 should be rejected, and this legislation should 
     be returned to the House Education and Workforce Committee 
     for further deliberation.
           Sincerely,
                                                    G. Roger King,
                                                   King Labor Law.
                                                   Alex MacDonald,
     Co-Chair, Littler Mendelson Workplace Policy Institute.
                                  ____

                                                     June 9, 2026.
     Re Policy and Operational Flaws of the Faster Labor Contracts 
         Act--H.R. 5408

     Hon. Tim Walberg,
     Chairman, House Committee on Education and Workforce, 
         Washington, DC.
       Dear Chairman Walberg: We are writing regarding H.R. 5408, 
     the Faster Labor Contracts Act (``FLCA''). This letter deals 
     with the bill's policy and operational flaws.
       The FLCA also has major policy defects. At bottom, it would 
     permit the government to mandate, through private arbitral 
     action, terms and conditions of employment and impose 
     extensive contract terms on employers, employees, and unions. 
     This has never happened in the country's history with respect 
     to private sector labor contracts. There is absolutely no 
     precedent for this type of government intrusion into the 
     workplace. Parties in the private sector should be permitted 
     to negotiate the terms of labor agreements without government 
     interference. The approach in this legislation is exceedingly 
     poor public policy. H.R. 5408 should be rejected on this 
     basis alone.
       Further, the pending legislation would prohibit employees 
     from voting on a government-imposed contract, which could be 
     binding on the employees for up to two (2) years. This lack 
     of employee scrutiny and the opportunity for an employee vote 
     is a substantial interference with employee rights and, on 
     this basis alone, H.R. 5408 should also be rejected.
       The pending legislation also has a number of other defects, 
     including the duration of mandated contract terms. There is 
     an extremely important difference that Members may not be 
     aware of regarding federal labor contract law and common law 
     contract law. Under common law contract law, the terms and 
     conditions set forth in an agreement do not continue after 
     the contract's expiration date. Absent some type of evergreen 
     or continuation clause, all parts or provisions of a common 
     law contract become null and void after the expiration date 
     of the contract. By way of contrast--and this is an extremely 
     important point for Members to understand--all provisions but 
     for very few minor exceptions of a collective bargaining 
     agreement negotiated between unions and employers continue in 
     full force and effect after the expiration date of the 
     agreement. Such a continuation of terms and conditions of 
     employment is a result of federal labor law requirements, 
     pursuant to the important U.S. Supreme Court decision in the 
     Katz case. Essentially, the Katz doctrine requires that no 
     party to a labor agreement can unilaterally change the terms 
     and conditions set forth in the expired labor contract, 
     absent mutual agreement of all parties. The practical impact 
     of the unilateral change doctrine is that contract terms set 
     forth in an initial agreement have a life expectancy of 
     literally decades after the agreement is negotiated.
       Employees working at a location covered by a collective 
     bargaining agreement, in addition to not having had the 
     opportunity to vote on whether they desire union 
     representation, would also be prohibited from voting on 
     whether they agree with certain labor contract provisions 
     mandated by a government-sanctioned private arbitration 
     panel. The provision in H.R. 5408 stating that a government-
     mandated initial contract would only last for two (2) years 
     is exceptionally misleading for the reasons just described. 
     In fact, the government-mandated contract terms in an initial 
     agreement would likely remain in place for decades and could 
     not be changed unilaterally unless mutually agreed upon by 
     all parties. This area of contract law under our federal 
     labor law system is particularly concerning given the 
     potential for government-mandated imposed agreements to 
     contain restrictions on an employer's ability to reshape its 
     business, to change important terms and conditions of 
     employment, and, in this ever-changing technical age, 
     including particularly the presence of AI, make important 
     entrepreneurial decisions. On this basis alone, H.R. 5408 
     should be rejected.

[[Page E575]]

       Additionally, the pending legislation omits or fails to 
     consider important statutory rights of employees, unions, and 
     employers under the NLRA. For example, H.R. 5408 omits the 
     right of unions and employers to appeal National Labor 
     Relations Board decisions on the composition of bargaining 
     units. At present, unions and employers who disagree with the 
     National Labor Relations Board's decisions on which 
     categories of employees should be included or excluded from a 
     bargaining unit can appeal those decisions to a federal court 
     of appeals. This is an extremely important right for all 
     stakeholders under the National Labor Relations Act, 
     particularly given the ever-changing nature of Board law and 
     its constant policy oscillation with respect to important 
     issues under the NLRA. There have been wide variations among 
     administrations in how the NLRA is to be interpreted and 
     applied. One of these important areas is the composition of 
     bargaining units. H.R. 5408 makes no provision whatsoever for 
     the continuation of this important appeal right.
       H.R. 5408 also fails to mention in any manner the right of 
     employers to unilaterally implement terms and conditions of 
     employment if an impasse if reached in negotiations. The 
     impasse doctrine under the NLRA has been in place for 
     decades. Although it is a high burden for employers to meet, 
     it is an important safety valve doctrine that permits an 
     employer to ultimately implement its last contract offer if a 
     deadlock or stalemate occurs in negotiations and no agreement 
     can be reached. It is essential that the impasse doctrine not 
     be interfered with--it needs to continue to be a part of our 
     checks and balances in our federal labor laws.
       H.R. 5408 is also silent on whether employees have the 
     right to strike under the various mandates included in this 
     legislation. An employee's right to strike is one of the 
     bedrock provisions of our federal labor law and also serves 
     as a safety valve for employees and unions to respond to what 
     they believe is employer overreach. H.R. 5408 does not 
     address this right to strike issue and would appear to 
     prohibit employees not only from voting on the final 
     government-mandated arbitration contract terms but from 
     rejecting such terms altogether and engaging in strike 
     activity. Again, on this point alone, H.R. 5408 should also 
     be rejected.
       Additionally, this legislation is replete with practical 
     problems and contains unrealistic time targets. For example, 
     the bill requires that negotiations begin within ten (10) 
     days of receiving a written request from the other party. 
     This ten-day requirement falls far short of the reality of 
     collective bargaining in this country. Neither unions nor 
     employers are prepared, within ten (10) days of a request to 
     begin bargaining, to engage in any meaningful exchange of 
     proposals. Indeed, it takes considerable time for parties to 
     begin to prepare for bargaining. For example, negotiating 
     committee members need to be selected. Negotiation dates and 
     locations must be agreed upon. Written contract proposals 
     must be developed, which are exceedingly important because 
     they have the potential to form the basis for the ultimate 
     agreement between the parties. Ground rules have to be 
     established--in fact, negotiation over ground rules often 
     takes weeks if not months because of issues such as whether a 
     media blackout should be imposed, location of bargaining, 
     questions of whether employees will be paid for all of their 
     time in negotiations, no smoking policies, issues of whether 
     negotiations can be recorded and/or available for online 
     access, and the list goes on. Additionally, first contracts 
     can be delayed by information requests from employers or 
     unions. In fact, one of the preferred approaches of certain 
     unions has been to file extensive information requests before 
     negotiations begin or at certain critical points during 
     negotiations, therefore significantly delaying the 
     negotiation process. It is important to remember that first 
     contracts form the basis of an agreement that may have a 
     lasting impact. Initial contract terms may be contained in 
     successive bargaining agreements for decades. Any experienced 
     negotiator, whether on the employer or union side, will tell 
     you that the first contract between parties is exceptionally 
     important. For reasons outlined above, once a contract 
     provision is in place, it cannot be removed in subsequent 
     agreements, even after contract expiration, absent a mutual 
     agreement by the parties.
       Further, the requirement that mediation occur within ninety 
     (90) days after the initial negotiation period is also 
     entirely unrealistic. At that point in their discussions, the 
     parties may not be anywhere near agreement on multiple 
     issues. Mediation is only effective when the parties have 
     reached well-defined positions on open issues that then can 
     be ``mediated'' by an outside party. The requirement 
     mandating ``interest arbitration'' within thirty (30) days 
     after the completion of mediation is also an unrealistic time 
     target. If mediation has had any positive impact on the 
     parties, they will need more than thirty (30) days of 
     negotiations to reach an ultimate agreement. There are other 
     impractical and unrealistic time targets in this legislation. 
     Suffice it to say, the time targets are not based on reality 
     and also include unrealistic expectations of assistance from 
     the Federal Mediation and Conciliation Service (``FMCS''), an 
     entity that has been slated by the Administration for phase-
     out or substantial curtailment of its services. The FMCS does 
     not have anywhere near the personnel to meet the obligations 
     this legislation would impose upon it.
       H.R. 5408 should be rejected, and this legislation should 
     be returned to the House Education and Workforce Committee 
     for further deliberation.
           Sincerely,
                                                    G. Roger King,
                                                   King Labor Law.

                                               Alex MacDonald,

                                       Co-Chair, Littler Mendelson
     Workplace Policy Institute
                                  ____

                                                     June 9, 2026.
     Re Constitutional Defects of the Faster Labor Contracts Act--
         H.R. 5408

     Hon. Tim Walberg,
     Chairman, House Committee on Education and Workforce, 
         Washington, DC.
       Dear Chairman Walberg: We are writing regarding H.R. 5408, 
     the Faster Labor Contracts Act (``FLCA''). This letter deals 
     with the bill's constitutional defects.
       Finally, the legislation has numerous and substantial 
     constitutional problems. Indeed, the provisions of this 
     legislation fly in the face of Supreme Court precedent, which 
     for a hundred years has told us that ``compulsory'' 
     arbitration violates due process. The bill also violates 
     well-established constitutional rules against delegating 
     government power to unaccountable, private decisionmakers. 
     But most problematically, the bill constitutionalizes every 
     collective bargaining agreement. Every government-mandated 
     collective bargaining agreement and every dispute about such 
     agreement will become a constitutional case. The result will 
     be chaos in our workplaces and congestion in our courts. This 
     approach will direct employer resources to litigation and 
     potentially decrease the amount of wages and benefits an 
     employer can provide to employees.
       There are due-process issues with this litigation. A 
     century ago, in three (3) separate cases, the Supreme Court 
     held that a state cannot force employers and workers to 
     decide the terms and conditions of their own workplaces 
     through government-mandated arbitration that ``deputized'' 
     private sector arbitrators to act as agents of the federal 
     government. These cases are known as the Wolff Packing 
     trilogy, after the name of the employer involved. The cases 
     came out of a Kansas law that required employers and workers 
     in certain industries to submit their disputes over wages and 
     other working conditions to a government agency. That agency 
     then set the terms for them through arbitration. And this 
     same law barred employees from striking during the 
     arbitration process.
       The Supreme Court had no problem finding that law 
     unconstitutional. Three times, the Court said that employers 
     and employees cannot be forced to make their contracts 
     through arbitration. Arbitration has to be agreed to by both 
     sides. Whatever power the government has to regulate working 
     conditions itself, it cannot impose a contract on private 
     parties through an arbitral process.
       Some individuals may argue that the Wolff Packing trilogy 
     is no longer good law. They are wrong.
       First, while we may have a different economy today and the 
     presence of new technology, we still have the same 
     Constitution. Due process means the same thing today that it 
     meant when the Framers adopted the Fifth Amendment. And due 
     process has meant, since the Magna Carta, that no one may be 
     deprived of their rights except by a generally applicable 
     law. While the government can set minimum standards applied 
     generally to all people and all business entities, it cannot 
     compel a special result for one employer and one union in a 
     government-imposed ``contract'' that specifically applies to 
     them and no one else. Congress cannot set aside the Framers' 
     vision just because some individuals and organizations 
     believe those freedoms are outdated.
       Second, the Wolff Packing decisions are still good Supreme 
     Court precedent. They have never been revisited or 
     overturned. The Congress does not have the option to overturn 
     Supreme Court precedent--only the Supreme Court can do that.
       There are also delegation issues with this legislation. 
     Article I of the Constitution says that ``all'' legislative 
     power is vested in Congress. Likewise, Article II states that 
     all executive power is vested in the President. The articles 
     don't say ``some'' power is vested in these branches; they 
     don't say that these branches have only as much power as they 
     decide not to give away. No--they say that all power is 
     vested in those branches. And they say that for a reason. 
     Congress and the President have to face the voters: every 
     election cycle, they are accountable to the people. If they 
     use public power in a way the people don't like, the people 
     can replace them. But that isn't true about private people. 
     If private people are given government power, they can use 
     that power without answering to anyone. And worse, the people 
     who are supposed to use that power--the Congress and the 
     President--can avoid responsibility for the results.
       That is why the Constitution does not permit the government 
     to delegate unlimited government power to private 
     individuals. The Congress cannot just say to some consultant, 
     go write the laws. Indeed, if Congress wants to utilize 
     private expertise, the government has to supervise the 
     private experts. Congress has to make sure that these private 
     people are only helping government, not making government 
     policy. Courts call this principle ``subordination.'' It 
     means that the private party has to be subordinate to some 
     accountable public official. The public official has to be 
     able to review, modify,

[[Page E576]]

     or reject what the private party does. Otherwise, the 
     Congress will have delegated power to private people without 
     the proper limits. This legislation clearly violates the 
     Vesting Clauses of the Constitution.
       That's exactly what this bill would do. After forcing 
     employers and workers into arbitration, it would assign their 
     case to a panel of private arbitrators. These arbitrators 
     would then be authorized to write an agreement and impose it 
     on the parties. Parties might object to the mandated 
     agreement. But no party would have any way to challenge it. 
     Once the arbitrators made a decision, the decision would be 
     final. No public official would review it; no public official 
     would make sure that it was fair. The arbitrators are private 
     people, and this bill would give them ultimate power to 
     regulate the workplace. That's a major Vesting Clause 
     problem.
       Some might argue that H.R. 5408 does not delegate any 
     government power. Is not this all about labor contracts? But 
     that would be wrong. These contracts are not really 
     contracts. A contract is a legally binding agreement that 
     parties mutually agree to; and parties under this proposed 
     legislation will have no right to challenge the imposed 
     contract terms. Instead, the terms are imposed by law--this 
     law. They are effectively regulations. And regulating the 
     workplace is a government power. So, the government cannot 
     give that power to private people without building in public 
     oversight. This bill has no oversight. It is flagrantly 
     unconstitutional.
       There are also Appointments Clause and delegation issues 
     under the proposed legislation. Under the Appointments 
     Clause, all officers of the United States have to be 
     appointed by the President and confirmed by the Senate. 
     Likewise, inferior officers have to be appointed by the 
     President, the head of a department, or a court. The line 
     between officers and inferior officers can be unclear. But it 
     is clear, however, that if someone has final say imposed by 
     legislation, that person is an inferior officer. So at 
     minimum, the person must be appointed by the president, a 
     department head, or a court.
       This bill has nothing like that. Instead, one arbitrator is 
     appointed by a union, one by an employer, and the third 
     arbitrator, unless mutually agreed upon by the parties, would 
     be appointed by the Federal Mediation and Conciliation 
     Service--which, as previously noted, does not have sufficient 
     personnel to even begin to undertake the mandated mediation 
     and arbitration procedures contained in this legislation. So, 
     private parties will have appointed individuals acting as 
     government officers, and there is no requirement that they be 
     appointed by a department head. And once they're appointed, 
     they have final say over the agreement's terms. At minimum, 
     that makes them inferior officers, who exercise ``substantial 
     executive power.'' This is clear from the holdings in cases 
     like the Supreme Court's decisions in Freytag v. Commissioner 
     and Lucia v. SEC, both of which dealt with lower-level 
     adjudicators. And in fact, in both cases, the parties who had 
     their cases tried by the adjudicators could at least appeal 
     to someone. The parties would have no right to appeal under 
     this bill. These arbitrators would have even more power. This 
     bill makes no effort to comply with the Constitution's 
     appointment rules.
       Perhaps the most important constitutional defect of this 
     bill is that it would turn every initial collective 
     bargaining agreement written by government-mandated private 
     arbitrators into a constitutional litigation battleground.
       Normally, private contracts do not have to satisfy the 
     Constitution. That's because the Constitution only concerns 
     government action. Under well-established NLRA case law, 
     employers and unions are required to bargain in good faith, 
     with the ultimate objective of reaching an agreement. It is 
     important to note, however, that well-established law also 
     permits any party in collective bargaining to refuse to agree 
     to the other party's proposals or positions. They can always 
     stand on their own positions. So anything they do agree on is 
     ultimately a private decision. And because it is a private 
     decision, the government does not have a say over the final 
     terms. In other words, the agreement involves no ``state 
     action.'' And when there's no state action, there's nothing 
     to trigger a constitutional analysis.
       This bill turns that principle on its head. It forces 
     employers and employees to accept an agreement imposed over 
     their objection. And it imposes that agreement by law. The 
     agreement, therefore, is not really an agreement at all: it 
     is a regulation. And because it's a regulation, it is state 
     action. Everything in it has to pass constitutional muster.
       That's a real problem. Today, if collective bargaining 
     agreements had to satisfy the Constitution, most of them 
     would fail. Let's just run through a few common examples. 
     Start with compulsory dues. Compulsory dues and fees are 
     payments that non-member employees have to pay to the union 
     in order to keep their job. In right-to-work states, they're 
     illegal. But twenty-four (24) states still allow them. And 
     when they are included in an agreement, employees have to pay 
     the dues or fees whether they want to or not.
       But the government cannot impose compulsory payments. In 
     Janus v. AFSCME, the Supreme Court said that the government 
     could not force public employees to pay fair-share fees 
     because there was not a sufficient government interest. That 
     was classic compelled speech, which the Constitution does not 
     allow.
       To date, courts have understood Janus as being limited to 
     the public sector. That's because only in the public sector 
     does the state directly force employees to pay the fees. But 
     once this bill passes, that distinction will disappear. The 
     government will be involved whenever an arbitral-created 
     contract requires fair-share fees. All of those contracts 
     will be open to attack in our courts. All of them will be 
     subject to First Amendment scrutiny.
       Today, many contracts give the union the right to come into 
     the workplace and speak with the employees at certain times. 
     In a private contract, that's fine. But under constitutional 
     analysis, it's a ``taking.'' In Cedar Point Nursery v. 
     Hassid, the Supreme Court held that California could not 
     force farmers to give unions access to their property. In 
     effect, California had extracted a right to access--an 
     ``easement.'' An easement is property. And the government 
     cannot take property without just compensation. California 
     gave the farmers no compensation, and neither would this 
     bill. So any time this bill imposed a contract with union 
     access rights, it would take property and violate the Fifth 
     Amendment.
       There are even more problems in the constitutional area 
     regarding this legislation. For example, grievance procedures 
     would have to comply with constitutional due process. No-
     strike clauses would have to comply with the Thirteenth 
     Amendment. The problems are endless. We have no idea how far 
     they would go, because the people who wrote this bill didn't 
     think about them. The authors have never explained how we're 
     going to deal with constitutionalizing every government-
     mandated initial collective bargaining agreement. They have 
     never explained how we're going to deal with the flood of 
     litigation that will wash over our courts. They have never 
     explained any of it--because they can't. This bill is a 
     constitutional disaster waiting to happen.
           Sincerely,
                                                    G. Roger King,
                                                   King Labor Law.

                                               Alex MacDonald,

                                       Co-Chair, Littler Mendelson
     Workplace Policy Institute.

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