Recently the Michigan Court of Appeals held that a trial court did, in fact, have subject matter jurisdiction over the portion of the plaintiffs' action that challenged the validity of a union security agreement and request for declaratory relief. Steffke v Taylor Fedn of Teachers AFT Local 1085, No. 317616 (Mich Ct App April 7, 2015). The Court of Appeals explained that the trial court's jurisdiction existed notwithstanding the Michigan Employment Relations Commission's exclusive jurisdiction over the plaintiffs' Public Employment Relations Act (PERA) claims.
In Steffke the Court instructed that the Michigan Employment Relations Commission had exclusive jurisdiction over the first two counts of the plaintiffs' case, which required an analysis of various PERA sections. However, the Court reiterated that both the Commission and the courts have concurrent jurisdiction in a case where both contractual and statutory claims are plead. The trial court in Steffke, for example, was found to have jurisdiction over the plaintiffs' last count: a claim for declaratory judgment that required an analysis of the United States Constitution and the union security agreement. In reaching this conclusion the Court reiterated that the Commission only has exclusive jurisdiction over some types of actions, and, as a result, each claim must be examined individually to determine whether the Commission has exclusive jurisdiction.