Anoka County, Anoka, Minnesota v. Law Enforcement Labor Services, Inc., Brooklyn Center, Minnesota

Summary

The court held that the Bureau of Mediation Services must first determine whether the employees' petitioned-for bargaining unit is an appropriate unit before considering an alternative unit. It further held that the Bureau may consider overfragmentation as an additional relevant factor, but may not allow its four-unit policy preference to control over the statutory factors or the factors the statute requires it to emphasize. The court reversed and remanded for the Bureau to reconsider the unit determination under the proper weighting of statutory factors.