## Facts

- In 2017, Iowa amended its Public Employment Relations Act (PERA) through House File 291.
- The amendments ended payroll deductions for public-employee union dues.
- The amendments created a classification based on whether a bargaining unit had at least 30% “public safety employees” (PSEs), a defined category including most police and firefighters but excluding corrections officers.
- Units with ≥30% PSEs retained broad mandatory bargaining subjects (e.g., wages, hours, and various working conditions) for the entire unit, including non-PSE members.
- Units with \<30% PSEs had mandatory bargaining largely limited to base wages; many prior mandatory subjects became permissive.
- AFSCME Iowa Council 61 and individual public employees challenged the amendments as unconstitutional, asserting unequal treatment of similarly situated public employees and alleging the changes burdened union membership and activity.
- The district court granted summary judgment to the State of Iowa and the Iowa Public Employment Relations Board (PERB), and AFSCME appealed.

## Issues

1. Whether PERA’s post-2017 distinction between bargaining units with ≥30% PSEs and those with \<30% PSEs violates equal protection under the Iowa Constitution.
2. Whether ending payroll deduction of union dues and restricting mandatory bargaining topics for many units violates public employees’ freedom of association under the Iowa Constitution.

## Decision

- The Iowa Supreme Court affirmed summary judgment for the State and PERB.
- Applying rational-basis review, the court held the ≥30% PSE classification and related bargaining differences did not violate Iowa equal protection.
- The court held the amendments did not violate freedom of association because employees remained free to join and support unions; the Constitution does not require the State to provide collective-bargaining structures or dues-deduction mechanisms.

## Legal Principles

- Under Iowa rational-basis review, economic and social legislation is upheld if any realistically conceivable legitimate governmental purpose supports the classification, even if the line drawn is imperfect.
- A statutory classification is not unconstitutional merely because it is arguably overinclusive or underinclusive; the legislature need not precisely tailor the threshold or prove empirical correctness.
- Freedom of association protects the right to join and participate in associations, but does not create a constitutional entitlement to state-facilitated payroll deduction of dues or to a particular scope of public-sector collective bargaining.

## Conclusion

The court upheld Iowa’s 2017 PERA amendments, concluding the legislature could reasonably distinguish bargaining units with substantial numbers of defined public safety employees to further legitimate interests such as labor peace and public health and safety, and that reducing statutory bargaining benefits and eliminating dues payroll deductions did not infringe the constitutional right to associate.


AFSCME Iowa Council 61 v. State, 928 N.W.2d 21 (Iowa 2019)