1 Marc J. Holley, “A Teacher Quality Primer” (Midland, Mich.: Mackinac Center for Public Policy, 2008), 19, accessed Feb. 7, 2014, http://goo.gl/SZYV1.“Pupil Membership History FY 1994-95 to FY 2014-15” (Michigan Senate Fiscal Agency, 2013), accessed Oct. 20, 2013, http://goo.gl/xOCx3.

2 “Public Act No. 101” (State of Michigan, July 19, 2011), accessed Feb. 7, 2014, http://goo.gl/sJbAV; “Public Act No. 100” (State of Michigan, July 19, 2011), accessed Feb. 7, 2014, http://goo.gl/E2fGhW; “Public Act No. 102” (State of Michigan, July 19, 2011), accessed Feb. 7, 2014, http://goo.gl/zYUg7; “Public Act No. 103” (State of Michigan, July 19, 2011), accessed Feb. 7, 2014, http://goo.gl/YMfcL.

3 MCL § 423.215(4).

4 For example, see MCL § 380.1249(9).

5 “Public Act No. 54” (State of Michigan, June 8, 2011), accessed Feb. 7, 2014, http://goo.gl/EM4Wfc.

6 “Public Act No. 205” (State of Michigan, Jan. 4, 2009), 21, accessed Feb. 19, 2014, http://goo.gl/lQ0C2k.

7 MCL § 380.1250(1).

8 Tom Gantert, “Study: Most School Districts Violating Merit Pay Law,” Michigan Capitol Confidential (Mackinac Center for Public Policy, Oct. 12, 2012), accessed Feb. 7, 2014, http://goo.gl/GNN5OO; Michael Van Beek, “Merit Pay Survey Results” (Mackinac Center for Public Policy, 2012), accessed Feb. 7, 2014, http://goo.gl/Erv6Uf.

9 “Public Act No. 100” (State of Michigan, July 19, 2011), accessed Feb. 7, 2014, http://goo.gl/E2fGhW; “Public Act No. 101” (State of Michigan, July 19, 2011), accessed Feb. 7, 2014, http://goo.gl/sJbAV; “Public Act No. 102” (State of Michigan, July 19, 2011), accessed Feb. 7, 2014, http://goo.gl/zYUg7.

10 Julie Mack, “New K-12 Teacher-Tenure Reforms Get Mixed Reviews,” MLive.com, July 4, 2011, accessed Feb. 7, 2014, http://goo.gl/Oj6mEU.

11 “Public Act No. 103” (State of Michigan, July 19, 2011), accessed Feb. 7, 2014, http://goo.gl/YMfcL.

12 Eric Griggs and Tom White, “Hot Topics in Labor: MASB and MASA Legislative Conference” (Michigan Association of School Boards, March 15, 2012).

13 Robert Schindler, “Prohibited Subjects of Bargaining: What They Mean, What They Don’t, and How to Use Them” (Michigan Negotiators Association, Oct. 9, 2013), accessed Feb. 7, 2014, http://goo.gl/VO8EWh.

14 Eric Griggs and Tom White, “Hot Topics in Labor: MASB and MASA Legislative Conference” (Michigan Association of School Boards, March 15, 2012); Robert Schindler, “Prohibited Subjects of Bargaining: What They Mean, What They Don’t, and How to Use Them” (Michigan Negotiators Association, Oct. 9, 2013), accessed Feb. 7, 2014, http://goo.gl/VO8EWh.

15 Patrick Wright, “Jurrians et al. v. Kent Intermediate School District et al.: Brief in Response to Defendants’ Motions to Dismiss” (Mackinac Center for Public Policy, Feb. 11, 2011), 16, accessed Feb. 20, 2014, http://goo.gl/Wjo5pn.

16 Eric Griggs and Tom White, “Hot Topics in Labor: MASB and MASA Legislative Conference” (Michigan Association of School Boards, March 15, 2012), 11.

17 Patrick Wright, “Jurrians et al. v. Kent Intermediate School District et al.: Brief in Response to Defendants’ Motions to Dismiss” (Mackinac Center for Public Policy, Feb. 11, 2011), accessed Feb. 20, 2014, http://goo.gl/Wjo5pn.

18 Ibid., 16.

19 “Agreement between the Allen Park Board of Education and the Allen Park Education Association” (Allen Park Public Schools, Aug. 26, 2013), 4, accessed Feb. 11, 2014, http://goo.gl/FUdY5c.

20 “Master Agreement 2012 - 2013 Avondale School District and Avondale Education Association, MEA/NEA” (Avondale School District, Sept. 1, 2012), 92, accessed Feb. 11, 2014, http://goo.gl/wLUek6.

21 “Agreement between Bay City Public Schools and Bay City Education Association Covering the Year 2011-2012” (School District of the City of Bay City, Jan. 27, 2012), 87, accessed Feb. 7, 2014, http://goo.gl/ytwvi3.

22 “Agreement between the Board of the Berkley School District and the Berkley Education Association, MEA/NEA” (Berkley School District, June 11, 2012), 86, accessed Feb. 7, 2014, http://goo.gl/bKfzCJ.

23 “Master Agreement: Chippewa Hills Board of Education/Chippeway Hills Education Association” (Chippewa Hills School District, June 26, 2012), 71, accessed Feb. 11, 2014, http://goo.gl/WXT9VD.

24 “Agreement between Crestwood School District and the Crestwood Federation of Teachers” (Crestwood School District, 2012), 61, accessed Feb. 25, 2014, http://goo.gl/RdMdoA.

25 “Collective Bargaining Agreement between the Fitzgerald Education Association, MEA/NEA and the Fitzgerald Board of Education” (Fitzgerald Public School District, March 21, 2013), 54, accessed Feb. 25, 2014, http://goo.gl/EH4fbz.

26 “Master Agreement Between The Fruitport Community Schools Board of Education and the Fruitport Education Association” (Fruitport Community Schools, Sept. 14, 2011), iii, accessed Feb. 10, 2014, http://goo.gl/Lds9si.

27 “Professional Negotiation Agreement Between Grand Haven Area and the Grand Haven Education Association” (Grand Haven Area Public Schools, Aug. 23, 2012), accessed Feb. 12, 2014, http://goo.gl/3Pm8t5.

28 “Master Agreement Between Hasings Area School System Board of Education And Hastings Education Association” (Hastings Area School System, Oct. 12, 2012), 41, accessed Feb. 7, 2014, http://goo.gl/sMjh8Y.

29 “Agreement Between L’Anse Creuse Board of Education and MEA-NEA, Local 1” (L’Anse Creuse Public Schools, March 25, 2013), 108, accessed Feb. 10, 2014, http://goo.gl/zPxYdg.

30 MCL § 423.215(3); MCL § 38.71 et al.

31 “Agreement between the Board of Education of the Midland Public Schools and the Midland City Education Association” (Midland Public Schools, March 25, 2013), 77, accessed Feb. 10, 2014, http://goo.gl/ZGHqT3.

32 “Collective Bargaining Agreement between Gull Lake Community Schools and Kalamazoo County Education Association” (Gull Lake Community Schools, Aug. 20, 2012), accessed Feb. 11, 2014, http://goo.gl/5e8KBu.

33 “Professional Agreement Between the Trenton Public Schools and the Trenton Education Association” (Trenton Public Schools, Aug. 26, 2013), 12, accessed Feb. 11, 2014, http://goo.gl/vIMB9f.

34 Ibid., 65.

35 For examples, see: “Master Agreement between the Eaton Rapids Education Association and the Eaton Rapids Public Schools Board of Education” (Eaton Rapids Public Schools, Sept. 1, 2011), accessed Feb. 11, 2014, http://goo.gl/lkXJhS.

36 For example, see: “Professional Agreement with Teachers between the Board of Education of the St. Joseph Public Schools and the Northern Berrien County Education Association, MEA/NEA Sept. 1, 2013 - Aug. 31, 2014” (St. Joseph Public Schools), 64, accessed Feb. 11, 2014, http://goo.gl/HkeHDD.

37 “Agreement Between the Plymouth-Canton Board of Education and the Plymouth-Canton Education Association MEA/NEA 2011-12” (Plymouth-Canton Community Schools, Aug. 31, 2012), accessed Feb. 7, 2014, http://goo.gl/JxgHG6.

38 “Master Agreement Betwen West Branch-Rose City Area School District and West Branch-Rose City Education Association” (West Branch-Rose City Area School District, July 1, 2012), accessed Feb. 10, 2014, http://goo.gl/jtd8nl.

39 Ibid., 46.

40 “Master Agreement Between The Fruitport Community Schools Board of Education and the Fruitport Education Association” (Fruitport Community Schools, Sept. 14, 2011), accessed Feb. 10, 2014, http://goo.gl/Lds9si.

41 “Public Act No. 102” (State of Michigan, July 19, 2011), accessed Feb. 7, 2014, http://goo.gl/zYUg7.

42 “Public Act No. 103” (State of Michigan, July 19, 2011), accessed Feb. 7, 2014, http://goo.gl/YMfcL.

43 “Public Act No. 102” (State of Michigan, July 19, 2011), accessed Feb. 7, 2014, http://goo.gl/zYUg7.

44 Eric Griggs and Tom White, “Hot Topics in Labor: MASB and MASA Legislative Conference” (Michigan Association of School Boards, March 15, 2012).

45 “2013-2015 Teachers Master Agreement” (Godwin Heights Public Schools, Sept. 1, 2012), 49, accessed Feb. 11, 2014, http://goo.gl/JyGt4O.

46 Ibid., 11.

47 “Master Agreement for the West Ottawa Public Schools and the West Ottawa Education Association” (West Ottawa Public Schools, Aug. 30, 2011), 13–17, accessed Feb. 11, 2014, http://goo.gl/359HIB.

48 “Teacher Effectiveness Ratings 2011-12 School Year” (Michigan Department o Education, 2012), accessed Feb. 11, 2014, http://goo.gl/CtRfLS.

49 “Master Agreement for the West Ottawa Public Schools and the West Ottawa Education Association” (West Ottawa Public Schools, Aug. 30, 2011), 17, accessed Feb. 11, 2014, http://goo.gl/359HIB.

50 “Agreement Between L’Anse Creuse Board of Education and MEA-NEA, Local 1” (L’Anse Creuse Public Schools, March 25, 2013), 56–57, accessed Feb. 10, 2014, http://goo.gl/zPxYdg.

51 “Teacher Effectiveness Ratings 2011-12 School Year” (Michigan Department o Education, 2012), accessed Feb. 11, 2014, http://goo.gl/CtRfLS.

52 “Master Agreement for the West Ottawa Public Schools and the West Ottawa Education Association” (West Ottawa Public Schools, Aug. 30, 2011), 88–89, accessed Feb. 11, 2014, http://goo.gl/359HIB.

53 Ibid., 88.

54 “Public Act No. 103” (State of Michigan, July 19, 2011), accessed Feb. 7, 2014, http://goo.gl/YMfcL.

55 “Agreement Between L’Anse Creuse Board of Education and MEA-NEA, Local 1” (L’Anse Creuse Public Schools, March 25, 2013), 116, accessed Feb. 10, 2014, http://goo.gl/zPxYdg.

56 Ibid., 77, 112.

57 “2012-2013 Master Agreement Between the Woodhaven-Brownstown School District and the Woodhaven-Brownstown Education Association” (Woodhaven-Brownstown School District, Sept. 1, 2012), 26–27, accessed Feb. 12, 2014, http://goo.gl/DL4vvi

58 Ibid., 52.

59 “Master Agreement 2012 - 2013 Avondale School District and Avondale Education Association, MEA/NEA” (Avondale School District, Sept. 1, 2012), 8–14, accessed Feb. 11, 2014, http://goo.gl/wLUek6.

60 Ibid., 92.

61 “Master Agreement between the Eaton Rapids Education Association and the Eaton Rapids Public Schools Board of Education” (Eaton Rapids Public Schools, Sept. 1, 2011), 20–24, accessed Feb. 11, 2014, http://goo.gl/lkXJhS.

62 “Agreement Between Board of Education of the Okemos Public School District and the Ingham Clinton Education Association” (Okemos Public School District, March 11, 2013), 15, accessed Feb. 12, 2014, http://goo.gl/P7pk7G.

63 “Portage Public Schools of the City of Portage and Portage Education Association, Incorporated, 2013 - 2014 Negotiations Agreement” (Portage Public Schools, May 20, 2013), 16, accessed Feb. 12, 2014, http://goo.gl/S25NAH.

64 “Agreement Between the Board of Education of Tecumseh Public Schools and the Lenawee County Education Association” (Tecumseh Public Schools, Dec. 17, 2012), accessed Feb. 12, 2014, http://goo.gl/wOikQK; “Professional Negotiation Agreement Between Grand Haven Area and the Grand Haven Education Association” (Grand Haven Area Public Schools, Aug. 23, 2012), accessed Feb. 12, 2014, http://goo.gl/3Pm8t5; “Master Contract Between the Oxford Community Schools and the Oxford Education Association” (Oxford Community Schools, Jan. 1, 2012), accessed Feb. 12, 2014, http://goo.gl/KDeVUm; “Lakeshore Pubic Schools Master Agreement: Lakeshore Education Assocation” (Lakeshore Public Schools, Aug. 1, 2013), accessed Feb. 12, 2014, http://goo.gl/3it8Z2; “Plainwell Community Schools and Plainwell Education Association Collective Bargaining Agreement” (Plainwell Community Schools, Aug. 5, 2013), accessed Feb. 12, 2014, http://goo.gl/ag8qAm; “Master Agreement Between the Haslett Education Association and the Haslett Board of Education” (Haslett Public Schools, Aug. 16, 2013), accessed Feb. 12, 2014, http://goo.gl/POeRb0.

65 “Agreement between Bay City Public Schools and Bay City Education Association Covering the Year 2011-2012” (School District of the City of Bay City, Jan. 27, 2012), 87–109, accessed Feb. 7, 2014, http://goo.gl/ytwvi3.

66 Ibid., 87.

67 Ibid., 96.

68 Ibid., 94.

69 Ibid.

70 Ibid., 90.

71 Ibid.

72 Ibid., 6.

73 “Agreement between the Allen Park Board of Education and the Allen Park Education Association” (Allen Park Public Schools, Aug. 26, 2013), 36, accessed Feb. 11, 2014, http://goo.gl/FUdY5c.

74 “Agreement Between the Plymouth-Canton Board of Education and the Plymouth-Canton Education Association MEA/NEA 2011-12” (Plymouth-Canton Community Schools, Aug. 31, 2012), 39, accessed Feb. 7, 2014, http://goo.gl/JxgHG6; “Agreement between the Allen Park Board of Education and the Allen Park Education Association” (Allen Park Public Schools, Aug. 26, 2013), 36, accessed Feb. 11, 2014, http://goo.gl/FUdY5c.

75 MCL 423.215(3)(k).

76 “Agreement Between the Plymouth-Canton Board of Education and the Plymouth-Canton Education Association MEA/NEA 2011-12” (Plymouth-Canton Community Schools, Aug. 31, 2012), accessed Feb. 7, 2014, http://goo.gl/JxgHG6.

77 Ibid., 21, 28.

78 Eric Griggs and Tom White, “Hot Topics in Labor: MASB and MASA Legislative Conference” (Michigan Association of School Boards, March 15, 2012).

79 Eric Griggs and Tom White, “Hot Topics in Labor: MASB and MASA Legislative Conference” (Michigan Association of School Boards, March 15, 2012); Robert Schindler, “Prohibited Subjects of Bargaining: What They Mean, What They Don’t, and How to Use Them” (Michigan Negotiators Association, Oct. 9, 2013), accessed Feb. 7, 2014, http://goo.gl/VO8EWh.

80 “Mackinac Center Legal Foundation Files Suit against 10 Kent County School Districts, Union,” Midland Daily News, Dec. 10, 2010, accessed Feb. 12, 2014, http://goo.gl/gpY80u.

81 MCL § 15.569.

82 “Agreement Between Allegan Public Schools and Allegan Education Association” (Allegan Public Schools, Aug. 13, 2013), 1, accessed Feb. 12, 2014, http://goo.gl/XRElcs.

83 “Agreement Between the Board of Education of Tecumseh Public Schools and the Lenawee County Education Association” (Tecumseh Public Schools, Dec. 17, 2012), 8, accessed Feb. 12, 2014, http://goo.gl/wOikQK.

84 “Contractual Agreement - Byron Center Education Association and the Board of Education, Byron Center Public Schools” (Byron Center Public Schools, Aug. 20, 2012), 16, accessed Feb. 12, 2014, http://goo.gl/BM54UV.

85 “Agreement between Chelsea School District Board of Education and the Washtenaw County Education Association (WCEA)/Chelsea Education Association (CEA), MEA, NEA” (Chelsea Public Schools, 2012), 5, accessed Feb. 28, 2014, http://goo.gl/iDK5nm.p>

86 “Master Agreement between the Chippewa Valley Schools Board of Education and the MEA-NEA Local 1, Chippewa Valley” (Chippewa Valley Schools, 2010), accessed Feb. 25, 2014, http://goo.gl/ C07ZWX; “Letter of Understanding Between MEA-NEA Local 1, Chippewa Valley and Chippewa Valley Schools Board of Education Contract Extension” (Chippewa Valley Schools, 2013), accessed Feb. 25, 2014, http://goo.gl/fPtGcu.

87 “Contract Agreement between the Comstock Park School Board and the Comstock Park Educational Employees Association” (Comstock Park Public Schools, 2013), 32, accessed Feb. 28, 2014, http://goo.gl/jwKRH7.

88 “Public Employee Relations Contract Coopersville Area Public Schools & Coopersville Education Association” (Coopersville Area Public Schools, 2013), 17, accessed Feb. 25, 2014, http://goo.gl/ llgnqy.

89 “Board of Education Dearborn Heights School District No. 7 and Wayne County MEA/NEA” (Dearborn Heights School District No. 7, 2013), 46, accessed Feb. 25, 2014, http://goo.gl/BlUm62.

90 “Agreement between the Board of Education of East Grand Rapids Public Schools and East Grand Rapids Educaiton Association” (East Grand Rapids Public Schools, Nov. 20, 2012), 8, accessed Feb. 25, 2014, http://goo.gl/54LxzV.

91 “Collective Bargaining Agreement between the Fitzgerald Education Association, MEA/NEA and the Fitzgerald Board of Education” (Fitzgerald Public School District, March 21, 2013), 21, accessed Feb. 25, 2014, http://goo.gl/EH4fbz.

92 “Professional Agreement between the Flushing Community Schools and Local 10 MEA/NEA (Flushing Unit)” (Flusing Community Schools, 2011), 22, accessed Feb. 25, 2014, http://goo.gl/Xlrwbo.

93 “Agreement Between the Gaylord Board of Education and the Gaylord Education Association/MEA” (Gaylord Community Schools, 2012), 17, accessed Feb. 25, 2014, http://goo.gl/qSq5dk.

94 “2013-2015 Teachers Master Agreement” (Godwin Heights Public Schools, Sept. 1, 2012), 1, accessed Feb. 11, 2014, http://goo.gl/ JyGt4O.

95 “Collective Bargaining Agreement between Gull Lake Community Schools and Kalamazoo County Education Association” (Gull Lake Community Schools, Aug. 20, 2012), 16, accessed Feb. 11, 2014, http://goo.gl/5e8KBu.

96 “Master Agreement between the Board of Education of the School District of the City of Holland and the Holland Education Association” (School District of the City of Holland, 2013), 7, accessed Feb. 25, 2014, http://goo.gl/RuOnzh.

97 “Master Agreement between the Hudsonville Board of Education and the Hudsonville Education Association” (Hudsonville Public Schools, 2012), 1, accessed Feb. 25, 2014, http://goo.gl/HZjYLa.

98 “Master Agreement between the Ionia Public Schools ’ Board of Education and the Ionia Education Association” (Ionia Public Schools, 2011), 1, accessed Feb. 25, 2014, http://goo.gl/qRSazx.

99 “Tentative Agreement between Kalamazoo Public Schools and Kalamazoo Education Association” (Kalamazoo Public Schools, 2012), 24, accessed Feb. 25, 2014, http://goo.gl/4Gw6fK.

100 “Master Agreement 2012-2015 Kearsley Community School District and the Kearsley Education Association” (Kearsley Community School District, 2012), 4, accessed Feb. 25, 2014, http://goo.gl/ ivkkGi.

101 “Master Agreement Between The Board of Education of the Kelloggsville Public Schools and the Kelloggsville Educational Association (KEA)” (Kelloggsville Public Schools, 2012), page “a,” accessed Feb. 25, 2014, http://goo.gl/VfYunR.

102 “Agreement between Board of Education of the Lapeer Community Schools and Lapeer Education 2012-2015” (Lapeer Community Schools, 2012), 79, accessed Feb. 25, 2014, http://goo.gl/IyOck3.

103 “Master Agreement between the Board of Education of the Lowell Area Schools, Lowell Education Association and the Kent County Education Association” (Lowell Area Schools, 2013), 18, accessed Feb. 25, 2014, http://goo.gl/8d714J.

104 “Marquette Area Education Association and Marquette Area Public Schools Master Agreement” (Marquette Area Public Schools, 2012), 35, accessed Feb. 25, 2014, http://goo.gl/ezKzS8.

105 “Agreement Between Marshall Public Schools Board of Education And Marshall Teachers Association, MEA/NEA” (Marshall Public Schools), 4, accessed Feb. 11, 2014, http://goo.gl/1SOIwF.

106 “Agreement between the Board of Education of the Midland Public Schools and the Midland City Education Association” (Midland Public Schools, March 25, 2013), Preamble, accessed Feb. 10, 2014, http://goo.gl/ZGHqT3.

107 “Master Agreement between the Milan Area School District and the Milan Education Association” (Milan Area School District, 2013), 5, accessed Feb. 25, 2014, http://goo.gl/mJJcpf.

108 “Interim Operating Rules Between Monroe Public Schools Board of Education And Monroe City Education Association MEA/NEA” (Monroe Public Schools, 2012), 52, accessed Feb. 25, 2014, http://goo.gl/056nbQ.

109 “Agreement between Board of Education of the Northview Public Schools and Kent County Education Association” (Northview Public Schools, 2013), 7, accessed Feb. 25, 2014, http://goo.gl/qqkW8R.

110 “Master Agreement between Northville Education Association and the Northville Public Schools” (Northville Public Schools, 2013), 1, accessed Feb. 25, 2014, http://goo.gl/p0dEl6.

111 “Agreement between Northwest Community Schools and the Jackson County Education Association” (Northwest Community Schools, 2013), 40, accessed Feb. 25, 2014, http://goo.gl/fs5Q9T.

112 “Agreement between the Plymouth-Canton Board of Education and the Plymouth-Canton Education Association MEA/NEA 2012-2015 (Reopener for Economics 2014/2015)” (Plymouth-Canton Community Schools, 2013), 69, accessed Feb. 25, 2014, http://goo.gl/KRYtjV.

113 “Master Agreement Between the Reeths-Puffer Education Association and the Reeths-Puffer Board of Education” (Reeths-Puffer School District, March 25, 2013), 1, accessed Feb. 12, 2014, http://goo.gl/RDrda4.

114 “Agreement Betwen Rockford Board of Education Rockford Public Schools and Kent County Education Association and Rockford Educational Association” (Rockford Public Schools, 2013), 19, accessed Feb. 25, 2014, http://goo.gl/JfcnLx.

115 “2012-2016 Master Agreement between the Board of Education of the South Lyon Community School District and the South Lyon Education Association, MEA/NEA” (South Lyon Community School District, 2012), 1, accessed Feb. 25, 2014, http://goo.gl/PXRsEI.

116 “Agreement between the Spring Lake Board of Educaiton and the Spring Lake Education Association MEA/NEA” (School District of Spring Lake), 47, accessed Feb. 11, 2014, http://goo.gl/Rk9sbq.

117 “Professional Agreement with Teachers between the Board of Education of the St. Joseph Public Schools and the Northern Berrien County Education Association, MEA/NEA September 1, 2012 - August 31, 2013” (St. Joseph Public Schools), 36, accessed Feb. 28, 2014, http://goo.gl/URqTUV.

118 “Professional Agreement Between the Trenton Public Schools and the Trenton Education Association” (Trenton Public Schools, Aug. 26, 2013), 65, accessed Feb. 11, 2014, http://goo.gl/vIMB9f.

119 “Master Agreement between the Walled Lake Board of Education and the Walled Lake Education Association, MEA-NEA” (Walled Lake Consolidated School District, 2012), 68, accessed Feb. 25, 2104, http://goo.gl/dZtdl9.

120 “Agreement between the Warren Consolidated Schools Board of Education and the Warren Education Association” (Warren Consolidated Schools, 2013), 89, accessed Feb. 25, 2014, http://goo.gl/gNStqH.

121 Warren Woods Board, “Agreement Between Warren Woods Board of Education and MEA-NEA, Local 1, Warren Woods Education Association” (Warren Woods Public Schools, March 26, 2013), 88, accessed Feb. 11, 2014, http://goo.gl/sNLDqb.

122 “Agreement between The Board of Education of the Waterford School District and the Waterford Education Association” (Waterford School District, 2013), 30, accessed Feb. 25, 2014, http://goo.gl/F45zEH.

123 “Master Agreement between the Waverly Board of Education and the Ingham/Clinton Education Association/Waverly Education Association, MEA/NEA” (Waverly Community Schools, 2013), 3, accessed Feb. 25, 2014, http://goo.gl/t6EG3f.

124 “Master Agreement between the West Bloomfield School District Board of Education and the West Bloomfield Education Association, MEA-NEA” (West Bloomfield School District, Sept. 1, 2012), 58, accessed Feb. 10, 2014, http://goo.gl/JL7tS3.

125 “Agreement by and between Western Education Association JCEA/MEA/NEA and Western School District Board of Education” (Western School District, 2013), 1, accessed Feb. 25, 2014, http://goo.gl/IlhN3E.

126 “2012-2013 Master Agreement Between the Woodhaven-Brownstown School District and the Woodhaven-Brownstown Education Association” (Woodhaven-Brownstown School District, Sept. 1, 2012), 52, accessed Feb. 12, 2014, http://goo.gl/DL4vvi.

127 “Professional Agreement between Brighton Area Schools Board of Education and Brighton Education Association” (Brighton Area Schools, 2012), 16, 55–57, accessed Feb. 28, 2014, http://goo.gl/Vkr7oc.

128 “Master Agreement Between Clarkston Community Schools And Clarkston Education Association/MEA-NEA” (Clarkston Community Schools, 2012), 24, 38–39, accessed Feb. 28, 2014, http://goo.gl/ jTSrI3.

129 “Professional Agreement 2008-2013” (Clintondale Community Schools, 2008), 19, accessed Feb. 28, 2014, http://goo.gl/RZdNIs. Though the contract was signed before the 2011 reforms took effect, a subsequent extension agreement was signed on March 13, 2013, which extended the identified prohibited provision.

130 “Master Agreement between the Eaton Rapids Education Association and the Eaton Rapids Public Schools Board of Education” (Eaton Rapids Public Schools, Sept. 1, 2011), accessed Feb. 11, 2014, http://goo.gl/lkXJhS.

131 “Master Contract between the Farmington Board of Education and the F.E.A., MEA/NEA 2007-2010”, 2007, 54–55, http://goo.gl/PbRHZx. Though this contract was signed before the 2011 reforms took effect, subsequent tentative agreements did not amend the identified prohibited language. For more, see: “Tentative Agreement between Farmington Public Schools and the Farmington Education Association, MEA-NEA” (Farmington Public Schools, 2013), accessed Feb. 28, 2014, http://goo.gl/LgVaVA.

132 “2009-2014 Agreement and 2014-2016 Extension Agreement Between the Board of Education of the Fraser Public Schools District and MEA-NEA, Local 1” (The Fraser Public Schools District, 2014), 33, 48–51, accessed Feb. 28, 2014, http://goo.gl/G9zC4G.

133 “Master Agreement Between The Fruitport Community Schools Board of Education and the Fruitport Education Association” (Fruitport Community Schools, Sept. 14, 2011), iii, accessed Feb. 10, 2014, http://goo.gl/Lds9si.

134 “2011-2014 Contract Agreement Between The Garden City Education Association And The Board of Education Of The School District of the City of Garden City Michigan” (The School District of the City of Garden City, 2011), 67, accessed Feb. 28, 2014, http://goo.gl/qXVSCg.

135 “Agreement between the Board of Education of the School District of the City of Hamtramck and the Hamtramck Federation of Teachers Local 1052” (School District of the City of Hamtramck, 2011), 11–12, accessed Feb. 28, 2014, http://goo.gl/Z2GhJY.

136 “Master Agreement Between Huron Education Association/MEA/NEA and Huron School District” (Huron School District, 2011), 16, accessed Feb. 28, 2014, http://goo.gl/NlgWTO.

137 “Master Agreement: Jenison Education Association and the Jenison Public School District” (Jenison Public School District, 2011), 16, 32, accessed Feb. 28, 2014, http://goo.gl/OfHJaD.

138 “Master Agreement between the Lakeview Teachers Represented by MEA/NEA Local 1 and the Lakeview Board of Education 2011-2015” (Lakeview Public Schools, 2011), 31, accessed Feb. 28, 2014, http://goo.gl/VzYp20.

139 “Master Agreement between Marysville Public Schools District and St. Clair County Education Association MEA/NEA” (Marysville Public Schools, 2012), 48, accessed Feb. 28, 2014, http://goo.gl/ fulQxz.

140 “Master Agreement between the Mason Board of Education of the Mason Public Schools and the Ingham Clinton Education Association” (Mason Public Schools, 2011), 30, accessed Feb. 28, 2014, http://goo.gl/Ag20RE.

141 “Teacher Collective Bargaining Contract Between the Melvindale-Northern Allen Park Public Schools And Melvindale-Northern Allen Park Federation of Teachers Local 1051, AFT, AFL-CIO” (Melvindale-Northern Allen Park Public Schools, 2012), 43–46, accessed Feb. 28, 2014, http://goo.gl/9xLFQG.

142 “Collective Bargaining Agreement Between the Oak Park Board of Education and the Oak Park Education Association/MEA/NEA 2012-2016” (Oak Park Schools, 2012), 29, 34–35, accessed Feb. 28, 2014, http://goo.gl/WctUCY.

143 “Master Agreement between the Riverview Board of Education and the Riverview Education Association September 1, 2011 through August 31, 2014” (Riverview School District, 2013), 30–32, accessed Feb. 28, 2014, http://goo.gl/wD4vtI.

144 “Master Agreement between Rochester Community Schools Board of Education and the Rochester Education Association, MEA/NEA” (Rochester Community Schools, 2012), 27, accessed Feb. 28, 2014, http://goo.gl/FvPv7G. A separate appendix on page 75 includes the language as well and states that if the law is modified or struck down, the district and union will renegotiate.

145 Language included in main contract does state that “Sections of the Article are unenforceable by law and thus non-grievable for certified staff,” though it does not provide any further guidance in how to interpret this language. “Agreement Betwen Rockford Board of Education Rockford Public Schools and Kent County Education Association and Rockford Educational Association” (Rockford Public Schools, 2013), 19, accessed Feb. 25, 2014, http://goo.gl/JfcnLx.

146 “Agreement between Sault Ste. Marie Area Public Schools Board of Education and the Sault Education Association” (Sault Ste. Marie Area Public Schools, 2012), 18–19, accessed Feb. 28, 2014, http://goo.gl/krCdlq.

147 Contract states that provisions that are “inconsistent” with the law will not be followed, but does not identifying them. “Master Agreement for the West Ottawa Public Schools and the West Ottawa Education Association” (West Ottawa Public Schools, Aug. 30, 2011), 13–17, 88, accessed Feb. 11, 2014, http://goo.gl/359HIB.

148 “Agreement Between The Board of Education of the School District of the City of Wyandotte and Wayne County-MEA/NEA Wyandotte Education Association” (School District of the City of Wyandotte, 2012), 10–12, accessed Feb. 28, 2014, http://goo.gl/7mTVDZ.

149 “Wyoming Public Schools Board of Education and the Kent County Education Association MEA/NEA” (Wyoming Public Schools, 2011), 16–17, 50–54, accessed Feb. 28, 2014, http://goo.gl/hXMtdU.