FLRA v. Aberdeen Proving Grounds - 485 U.S. 409 (1988)
U.S. Supreme Court
FLRA v. Aberdeen Proving Grounds, 485 U.S. 409 (1988)
FLRA v. Aberdeen Proving Grounds
Argued February 23, 1988
Decided April 4, 1988
485 U.S. 409
Title VII of the Civil Service Reform Act of 1978 generally requires that federal agencies and labor unions bargain in good faith concerning terms and conditions of employment. A statutory exemption provides that an agency has a duty to bargain when an agency rule or regulation is involved "only if the [Federal Labor Relations Authority (Authority)] has determined . . . that no compelling need . . . exists for the rule or regulation," 5 U.S.C. § 7117(a)(2), and details procedures for making that determination. § 7117(b). When respondent Aberdeen Proving Ground refused to negotiate an administrative leave proposal by its employees' union because the proposal conflicted with agency regulations, the union filed an unfair labor practice charge with the Authority. An Administrative Law Judge held in respondent's favor, finding that the proposal was inconsistent with agency regulations and was not subject to negotiations because the Authority had not previously determined under § 7117(b) that there was no compelling need for the regulations. The Authority reversed, holding, inter alia, that a compelling need determination may be unified with an unfair labor practice proceeding. The Court of Appeals reversed on the ground that a § 7117(b) negotiability appeal is the sole means of determining a compelling need question.
Held: Section 7117(b) provides the exclusive procedure for determining whether there is a compelling need for an agency regulation. The plain language of Title VII unambiguously provides that the procedure specified in § 7117(b) is exclusive, rather than one of multiple options. This reading of Title VII is consistent with the statute's legislative history and asserted purpose of achieving a balance between the rights of federal employees to bargain collectively and the public interest in effective government.