## Facts

- A federal employees’ union representing U.S. Geological Survey employees negotiated a basic collective-bargaining agreement with the Department of the Interior.
- The union proposed a clause requiring the agency, at the union’s request, to bargain during the contract term over matters not covered in the original agreement (union-initiated midterm bargaining).
- Relying on circuit precedent, the agency refused to bargain over the proposed midterm-bargaining clause.
- The Federal Labor Relations Authority (FLRA) treated the refusal as an unfair labor practice and ordered the agency to bargain over the clause.
- The Fourth Circuit set aside the FLRA’s order, concluding the Federal Service Labor-Management Relations Statute barred a contractual obligation to engage in union-initiated midterm bargaining.
- The Supreme Court granted review to resolve conflicting circuit interpretations about whether the Statute itself answers the midterm-bargaining question.

## Issues

1. Whether the Federal Service Labor-Management Relations Statute itself requires or forbids union-initiated midterm bargaining (and bargaining over a midterm-bargaining clause).
2. Whether Congress instead delegated to the FLRA the authority to determine, within statutory bounds, whether and to what extent midterm bargaining must occur.
3. What level of judicial deference applies to the FLRA’s interpretation of the Statute on midterm bargaining.

## Decision

- The Supreme Court vacated the Fourth Circuit’s judgment and remanded.
- The Court held that the Statute delegates to the FLRA the legal authority to decide whether parties must engage in midterm bargaining or bargaining about a midterm-bargaining clause.
- The Court concluded that the relevant statutory language is ambiguous as to midterm bargaining and does not support categorical judicial rules either requiring or prohibiting it.
- The Court instructed the Fourth Circuit to assess whether the FLRA’s position was reasonable and consistent with the Statute under the appropriate deferential standard.

## Legal Principles

- When a statute administered by an agency is ambiguous on a disputed point, courts generally must defer to the agency’s reasonable interpretation.
- The Federal Service Labor-Management Relations Statute’s duty to bargain in good faith does not, by its text alone, conclusively resolve whether union-initiated midterm bargaining is required or forbidden.
- The FLRA’s broad adjudicatory and policymaking authority under the Statute supports treating midterm-bargaining rules as a matter for agency elaboration, subject to reasonableness review.
- The same delegation applies to whether an agency must bargain, during term negotiations, over including a contractual clause that would require midterm bargaining.

## Conclusion

The Court did not decide whether union-initiated midterm bargaining must occur; it held the Statute leaves that question to the FLRA, and reviewing courts must evaluate the FLRA’s resolution under a deferential reasonableness standard.


Nat’l Fed’n of Fed. Emps., Loc. 1309 v. Dep’t of the Interior, 526 U.S. 86 (1999)