Right-to-work law

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In the context of labor law in the United States, the term right-to-work laws refers to state laws that prohibit union security agreements between employers and labor unions. Such agreements can be incorporated into union contracts to require employees who are not union members to contribute to the costs of union representation. Unlike the right to work definition as a human right in international law, U.S. right-to-work laws do not aim to provide a general guarantee of employment to people seeking work but rather guarantee an employee's right to refrain from being a member of a labor union.

Contents

The 1947 federal Taft–Hartley Act governing private sector employment prohibits the "closed shop" in which employees are required to be members of a union as a condition of employment, but allows the union shop or "agency shop" in which employees pay a fee for the cost of representation without joining the union. [1] Individual U.S. states set their own policies for state and local government employees (i.e. public sector employees). Twenty-eight states have right-to-work policies (either by statutes or by constitutional provision). [2] [3] In 2018, the U.S. Supreme Court ruled that agency shop arrangements for public sector employees were unconstitutional in the case Janus v. AFSCME .

History

Origins

The original use of the term right to work was coined by French socialist leader Louis Blanc before 1848. [4] According to the American Enterprise Institute, the modern usage of the term right to work was coined by Dallas Morning News editorial writer William Ruggles in 1941. [5]

According to PandoDaily , the modern term was coined by Vance Muse, a Republican Party operative who headed the Christian American Association, an early right-to-work advocacy group, to replace the term "American Plan" after it became associated with the anti-union violence of the First Red Scare. [6] Muse used racial segregationist arguments in advocating for anti-union laws. [7] [8] [6] [9] [10]

According to Slate , right-to-work laws are derived from legislation forbidding unions from forcing strikes on workers, as well as from legal principles such as freedom of contract, which sought to prevent passage of laws regulating workplace conditions. [11]

Wagner Act (1935)

The National Labor Relations Act, generally known as the Wagner Act, was passed in 1935 as part of President Franklin D. Roosevelt's "Second New Deal". Among other things, the act provided that a company could lawfully agree to be any of the following:

The act tasked the National Labor Relations Board, which had existed since 1933, with overseeing the rules.

Taft–Hartley Act (1947)

In 1947, the U.S. Congress passed the Labor Management Relations Act of 1947, generally known as the Taft–Hartley Act, over President Harry S. Truman's veto. The act repealed some parts of the Wagner Act, including outlawing the closed shop. Section 14(b) of the Taft–Hartley Act also authorizes individual states (but not local governments, such as cities or counties) to outlaw the union shop and agency shop for employees working in their jurisdictions. Any state law that outlaws such arrangements is known as a right-to-work state.

Current status

The federal government operates under open shop rules nationwide, but many of its employees are represented by unions. Unions that represent professional athletes have written contracts that include particular representation provisions (such as in the National Football League), [13] but their application is limited to "wherever and whenever legal," as the Supreme Court has clearly held that the application of a right-to-work law is determined by the employee's "predominant job situs". [14] Players on professional sports teams in states with right-to-work laws are thus subject to those laws and cannot be required to pay any portion of union dues as a condition of continued employment. [15]

Arguments for and against

Rights of dissenting minority and due process

The first arguments concerning the right to work centered on the rights of a dissenting minority with respect to an opposing majoritarian collective bargain. President Franklin Roosevelt's New Deal had prompted many U.S. Supreme Court challenges, including those regarding the constitutionality of the National Industry Recovery Act (NIRA) of 1933. In 1936, as a part of its ruling in Carter v. Carter Coal Co. the Court ruled against mandatory collective bargaining, stating: [16]

The effect, in respect to wages and hours, is to subject the dissentient minority ... to the will of the stated majority . ... To 'accept' in these circumstances, is not to exercise a choice, but to surrender to force. The power conferred upon the majority is, in effect, the power to regulate the affairs of an unwilling minority. This is legislative delegation in its most obnoxious form; for it is not even delegation to an official or an official body ... but to private persons . ... [A] statute which attempts to confer such power undertakes an intolerable and unconstitutional interference with personal liberty and private property. The delegation is so clearly arbitrary, and so clearly a denial of rights safeguarded by the due process clause of the Fifth Amendment, that it is unnecessary to do more than refer to decisions of this Court which foreclose the question.

Freedom of association

Besides the Supreme Court, other proponents of right-to-work laws also point to the U.S. Constitution and the right to freedom of association. They argue that workers should both be free to join unions or to refrain, and thus, sometimes refer to states without right-to-work laws as forced unionism states. These proponents argue that by being forced into a collective bargain, what the majoritarian unions call a fair share of collective bargaining costs, is actually financial coercion and a violation of freedom of choice. An opponent to the union bargain is forced to financially support an organization for which they did not vote in order to receive monopoly representation for which they have no choice. [17] [ citation needed ]

The Seventh-day Adventist Church discourages the joining of unions, [18] citing the writings of Ellen White, one of the church's founders, and what writer Diana Justice calls the "loss of free will" that occurs when a person joins a labor union.

Unfairness

Proponents such as the Mackinac Center for Public Policy contend that it is unfair that unions can require new and existing employees to either join the union or pay fees for collective bargaining expenses as a condition of employment under union security agreement contracts. [19] Other proponents contend that unions may still be needed in new and growing sectors of the economy, for example the voluntary and third party sectors, to assure adequate benefits for new immigrant, part-time aides such as the direct support professional workforce.

Political contributions

Right-to-work proponents, including the Center for Union Facts, contend that political contributions made by unions are not representative of the union workers. [20] The agency shop portion of this had previously been contested with support of National Right to Work Legal Defense Foundation in Communications Workers of America v. Beck , resulting in "Beck rights" preventing agency fees from being used for expenses outside of collective bargaining if the non-union worker notifies the union of their objection. [21] The right to challenge the fees must include the right to have it heard by an impartial fact finder. [22] Beck applies only to unions in the private sector, given agency fees were struck down for public-sector unions in Janus v. AFSCME in 2018.

Free riders

Opponents, such as Richard Kahlenberg, [2] [23] have argued that right-to-work laws simply "gives employees the right to be free riders—to benefit from collective bargaining without paying for it." [24] [25] Benefits the dissenting union members would receive despite not paying dues also include representation during arbitration proceedings. [26] In Abood v. Detroit BoE , the Supreme Court of the United States permitted public-sector unions to charge non-members agency fees so that employees in the public sector could be required to pay for the costs of representation, even as they opted not to be a member, as long as these fees are not spent on the union's political or ideological agenda. This decision was reversed, however, in Janus v. AFSCME , with the Supreme Court ruling that such fees violate the First Amendment in the case of public-sector unions, arguing that all bargaining by a public-sector union can be considered political activity.

Freedom of contract and association

Opponents argue that right-to-work laws restrict freedom of association, and limit the sorts of agreements that individuals acting collectively can make with their employer by prohibiting workers and employers from agreeing to contracts that include fair share fees. They also argue that American law imposes a duty of fair representation on unions, so non-members in right-to-work states can force unions to provide grievance services without compensation that are paid by union members. [27] Kahlenberg and Marvit also argue that, at least in efforts to pass a right-to-work law in Michigan, excluding police and firefighter unions—traditionally less hostile to Republicans—from the law caused some to question claims that the law was simply an effort to improve Michigan's businesses climate, not to seek partisan advantage. [24]

In December 2012, libertarian writer J. D. Tuccille wrote in Reason : "I consider the restrictions right-to-work laws impose on bargaining between unions and businesses to violate freedom of contract and association. ... I'm disappointed that the state has, once again, inserted itself into the marketplace to place its thumb on the scale in the never-ending game of playing business and labor off against one another. ... This is not to say that unions are always good. It means that, when the state isn't involved, they're private organizations that can offer value to their members." [28]

Studies of economic effect

Many studies of the effect of right-to-work laws exist but they find substantially different results. Studies have found both "some positive effect on job growth" and no effect. [29] A 2019 paper in the American Economic Review by economists from MIT, Stanford, and the U.S. Census Bureau, which surveyed 35,000 U.S. manufacturing plants, found that "the business environment, as measured by right-to-work laws, boosts incentive management practices." [30] According to a 2020 study published in the American Journal of Sociology , right-to-work laws lead to greater economic inequality by indirectly reducing the power of labor unions. [31] Looking at the growth of states in the Southeast following World War II, economist Tim Bartik says that while these states have right-to-work laws, they have also benefited from "factors like the widespread use of air conditioning and different modes of transportation that helped decentralize manufacturing." [32]

Economist Thomas Holmes argues that it is difficult to analyze right-to-work laws by comparing states because of other similarities between states that have passed these laws. For instance, right-to-work states often have some strong pro-business policies, making it difficult to isolate the effect of right-to-work laws. [33] Holmes compared counties close to the border between states with and without right-to-work laws, thereby holding constant an array of factors related to geography and climate. He found that the cumulative growth of employment in manufacturing in the right-to-work states was 26% greater than that in the non-right-to-work states. [34] Given the study design, Holmes writes that "my results do not say that it is right-to-work laws that matter, but rather that the 'pro-business package' offered by right-to-work states seems to matter." [35] Moreover, as noted by Kevin Drum and others, [36] this result may reflect business relocation rather than an overall enhancement of economic growth since, as Drum writes, "businesses prefer locating in states where costs are low and rules are lax". [37]

Polling

In January 2012, in the immediate aftermath of passage of Indiana's right-to-work law, a Rasmussen Reports [38] telephone survey found that 74% of likely voters disagreed with the question "Should workers who do not belong to a union be required by law to pay union dues if the company they work for is unionized?" but found that "most also don't think a non-union worker should enjoy benefits negotiated by the union." [39]

In January through March 2013, 43% of those polled believed that the law would help Michigan's economy, while 41% believed that it would hurt. [40] [41]

Political support

In 2012, President Barack Obama opposed right-to-work legislation in Michigan. [42] In 2017, Republican members of Congress introduced legislation for a national right-to-work law. [43]

U.S. states with right-to-work laws

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  Right-to-work law
  No right-to-work law

As of May 2024, following 26 states have right-to-work laws: [44] [45]

The territory of Guam also has right-to-work laws. [54]

Ohio allows employees to opt out from joining a union, but unions are allowed to charge a typically smaller fee for employees that opted out. [55]

Local or repealed laws

Some states had right-to-work laws in the past, but repealed them or had them declared invalid. There are also some counties and municipalities located in states without right-to-work laws that have passed local laws to ban union security agreements.

Delaware

Seaford passed a right-to-work ordinance in 2018, despite the State Solicitor disputing the authority of local governments to do so under Delaware law. [56] [57] Later that year, the Delaware General Assembly blocked the municipal ordinance. [58]

Illinois

Lincolnshire passed a local right-to-work ordinance, but it was struck down by the U.S. Seventh Circuit Court of Appeals. [59] An appeal to the U.S. Supreme Court resulted in the case being vacated as being moot because in the intervening period Illinois had passed the Illinois Collective Bargaining Freedom Act to invalidate such local ordinances. [60] [61] [62]

In a 2022 referendum, voters in Illinois approved a state constitutional amendment establishing a right to collective bargaining. The amendment also prevents any future state legislature or local government from passing a right-to-work law. [63]

Indiana

Before its passage in 2012, the Republican-controlled Indiana General Assembly passed a right-to-work bill in 1957, which led to the Democratic takeover of Indiana's Governor's Mansion and General Assembly in the coming elections, and eventually, the new Democratic-controlled legislature repealing the right-to-work law in 1965. [64] Right-to-work was subsequently reenacted in 2012. [49]

Kentucky

On November 18, 2016, the U.S. Sixth Circuit Court of Appeals upheld the right of local governments to enact local right-to-work laws in Kentucky. Kentucky had 12 local ordinances. A statewide law was subsequently enacted in 2017. [65]

Michigan

Michigan adopted a right-to-work bill in 2012. [66] After Democrats gained a trifecta in 2023, the legislature passed a bill repealing the right-to-work law, which was subsequently signed into law by Governor Whitmer and took effect in 2024. [67]

Missouri

The legislature passed a right-to-work bill in 2017, but the law was defeated in a 2018 referendum before it could take effect. [68] [69] [70] [71]

New Hampshire

New Hampshire adopted a right-to-work bill in 1947, but it was repealed in 1949 by the state legislature and governor. [72]

In 2017, a proposed right to work bill was defeated in the New Hampshire House of Representatives 200–177. [73] In 2021, the same bill was reintroduced but again defeated in the House of Representatives 199–175. [74]

New Mexico

New Mexico law previously did not explicitly prohibit nor allow mandatory union membership as a condition of employment at the statewide level, thereby leaving it up to local jurisdictions to establish their own right-to-work policies. Several counties, notably Chaves, Eddy, Lea, Lincoln, McKinley, Otero, Roosevelt, Sandoval, San Juan, and Sierra counties, in addition to Ruidoso village adopted such laws. [75] [76] [77] [78] [79] In 2019, the New Mexico Legislature approved legislation that prohibits local right-to-work laws and further states that union membership and the payment of union dues may be required as a condition of employment in workplaces subject to a collective bargaining agreement; it was signed by governor Michelle Lujan Grisham. [80] In 2020, New Mexico's legislature passed House Bill 364 that authorizes and promotes the use of card check protocols for workers considering organizing into a labor union. [81] New Mexico does not currently require Project Labor Agreements for state-sponsored projects, but some local jurisdictions (notably Bernalillo County and the City of Albuquerque) have ordinances in place requiring Project Labor Agreements for locally-sponsored projects that exceed specified dollar-value thresholds. [82] [83]

See also

Related Research Articles

Labour laws, labour code or employment laws are those that mediate the relationship between workers, employing entities, trade unions, and the government. Collective labour law relates to the tripartite relationship between employee, employer, and union.

<span class="mw-page-title-main">National Labor Relations Act of 1935</span> 1935 U.S. federal labor law

The National Labor Relations Act of 1935, also known as the Wagner Act, is a foundational statute of United States labor law that guarantees the right of private sector employees to organize into trade unions, engage in collective bargaining, and take collective action such as strikes. Central to the act was a ban on company unions. The act was written by Senator Robert F. Wagner, passed by the 74th United States Congress, and signed into law by President Franklin D. Roosevelt.

Collective bargaining is a process of negotiation between employers and a group of employees aimed at agreements to regulate working salaries, working conditions, benefits, and other aspects of workers' compensation and rights for workers. The interests of the employees are commonly presented by representatives of a trade union to which the employees belong. A collective agreement reached by these negotiations functions as a labour contract between an employer and one or more unions, and typically establishes terms regarding wage scales, working hours, training, health and safety, overtime, grievance mechanisms, and rights to participate in workplace or company affairs. Such agreements can also include 'productivity bargaining' in which workers agree to changes to working practices in return for higher pay or greater job security.

In labor law, a union shop, also known as a post-entry closed shop, is a form of a union security clause. Under this, the employer agrees to either only hire labor union members or to require that any new employees who are not already union members become members within a certain amount of time. Use of the union shop varies widely from nation to nation, depending on the level of protection given trade unions in general.

A union security agreement is a contractual agreement, usually part of a union collective bargaining agreement, in which an employer and a trade or labor union agree on the extent to which the union may compel employees to join the union, and/or whether the employer will collect dues, fees, and assessments on behalf of the union.

<span class="mw-page-title-main">United States labor law</span> US laws on fair pay and conditions, unions, democracy, equality and security at work

United States labor law sets the rights and duties for employees, labor unions, and employers in the US. Labor law's basic aim is to remedy the "inequality of bargaining power" between employees and employers, especially employers "organized in the corporate or other forms of ownership association". Over the 20th century, federal law created minimum social and economic rights, and encouraged state laws to go beyond the minimum to favor employees. The Fair Labor Standards Act of 1938 requires a federal minimum wage, currently $7.25 but higher in 29 states and D.C., and discourages working weeks over 40 hours through time-and-a-half overtime pay. There are no federal laws, and few state laws, requiring paid holidays or paid family leave. The Family and Medical Leave Act of 1993 creates a limited right to 12 weeks of unpaid leave in larger employers. There is no automatic right to an occupational pension beyond federally guaranteed Social Security, but the Employee Retirement Income Security Act of 1974 requires standards of prudent management and good governance if employers agree to provide pensions, health plans or other benefits. The Occupational Safety and Health Act of 1970 requires employees have a safe system of work.

An open shop is a place of employment at which one is not required to join or financially support a union as a condition of hiring or continued employment.

The duty of fair representation is incumbent upon Canadian and U.S. labor unions that are the exclusive bargaining representative of workers in a particular group. It is the obligation to represent all employees fairly, in good faith, and without discrimination.

<span class="mw-page-title-main">Union busting</span> Efforts to prevent or hinder unionization among workers

Union busting is a range of activities undertaken to disrupt or weaken the power of trade unions or their attempts to grow their membership in a workplace.

Financial Core refers to a legal carve-out that permits workers opposed to participating in a labor union to be employed under the benefits of a union's contracts without compelling them to be a member of that union.

Japanese labour law is the system of labour law operating in Japan.

Lehnert v. Ferris Faculty Association, 500 U.S. 507 (1991), deals with First Amendment rights and unions in public employment.

The National Right to Work Legal Defense Foundation, established in 1968, is a nonprofit organization that seeks to advance right-to-work laws in the United States.

Davenport v. Washington Education Association, 551 U.S. 177 (2007), is a ruling by the Supreme Court of the United States in which the Court held that it does not violate the First Amendment for a state to require its public-sector unions to receive affirmative authorization from a non-member before spending that nonmember's agency fees for election-related purposes.

Communications Workers of America v. Beck, 487 U.S. 735 (1988), is a decision by the United States Supreme Court which held that, in a union security agreement, unions are authorized by statute to collect from non-members only those fees and dues necessary to perform its duties as a collective bargaining representative. The rights identified by the Court in Communications Workers of America v. Beck have since come to be known as "Beck rights", and defining what Beck rights are and how a union must fulfill its duties regarding them is an active area of modern United States labor law.

Abood v. Detroit Board of Education, 431 U.S. 209 (1977), was a US labor law case where the United States Supreme Court upheld the maintaining of a union shop in a public workplace. Public school teachers in Detroit had sought to overturn the requirement that they pay fees equivalent to union dues on the grounds that they opposed public sector collective bargaining and objected to the political activities of the union. In a unanimous decision, the Court affirmed that the union shop, legal in the private sector, is also legal in the public sector. They found that non-members may be assessed agency fees to recover the costs of "collective bargaining, contract administration, and grievance adjustment purposes" while insisting that objectors to union membership or policy may not have their dues used for other ideological or political purposes.

California Proposition 18 was on the November 4, 1958 California ballot measure as an initiated constitutional amendment. This measure is more commonly referred as the "right to work" law and would have added a new provision, Section 1-A to Article 1 of the State Constitution. The amendment would “prohibit employers and employee organizations from entering into collective bargaining or other agreements which establish membership in a labor organization, or payment of dues or charges of any kind, as a condition of employment or continued employment.” That is, making union membership voluntary, rather than compulsory, for employment.

Knox v. Service Employees International Union, 567 U.S. 298 (2012), is a United States constitutional law case. The United States Supreme Court held in a 7–2 decision that Dianne Knox and other non-members of the Service Employees International Union did not receive the required notice of a $12 million assessment the union charged them to raise money for the union's political fund. In a tighter 5–4 ruling, the court further held that the long-standing precedent, the First Amendment requirement that non-union members covered by union contracts be given the chance to "opt out" of special fees was insufficient. Setting new precedent, the majority ruled that non-members shall be sent notice giving them the option to opt into special fees.

Janus v. American Federation of State, County, and Municipal Employees, Council 31, No. 16-1466, 585 U.S. ___ (2018), abbreviated Janus v. AFSCME, is a landmark decision of the US Supreme Court on US labor law, concerning the power of labor unions to collect fees from non-union members. Under the Taft–Hartley Act of 1947, which applies to the private sector, union security agreements can be allowed by state law. The Supreme Court ruled that such union fees in the public sector violate the First Amendment right to free speech, overruling the 1977 decision in Abood v. Detroit Board of Education that had previously allowed such fees.

<span class="mw-page-title-main">2022 Illinois elections</span>

A general election was held in the U.S. state of Illinois on November 8, 2022. The elections for United States Senate and United States House of Representatives, Governor, statewide constitutional officers, Illinois Senate, and Illinois House were held on this date.

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  45. ↑ Neuman, Scott (August 8, 2018). "Missouri Blocks Right-To-Work Law". NPR . Archived from the original on August 27, 2018. Retrieved August 26, 2019. Currently, 27 states and Guam have laws allowing employees in private-sector unionized workplaces to opt out of union membership and union fees.
  46. ↑ "Right to Work Laws: Arizona | National Right to Work Legal Defense Foundation". Nrtw.org. Retrieved May 2, 2015.
  47. ↑ "Florida Constitution". The Florida Legislature. Retrieved July 11, 2014.
    "Right to Work States: Florida | National Right to Work Legal Defense Foundation". Nrtw.org. Retrieved May 2, 2015.
  48. ↑ Wines, William A. (1988). "An Analysis of the 1986 Right-to-Work Referendum in Idaho". Labor Law Journal. 39: 622.
  49. 1 2 Schneider, Mary Beth; Sikich, Chris (February 1, 2012). "Indiana Gov. Daniels signs 'right to work' bill; protest winds through Super Bowl Village". The Indianapolis Star . Retrieved February 1, 2012.
  50. ↑ "South Carolina Code of Laws § 41-7-10".
  51. ↑ "State Right-to-Work Timeline". National Right to Work Committee. Retrieved October 29, 2017.
    "LABOR CODE CHAPTER 101. LABOR ORGANIZATIONS". Statutes.legis.state.tx.us. Retrieved May 2, 2015.
  52. ↑ DePillis, Lydia (February 4, 2016). "West Virginia House passes right-to-work bill after harsh debate". The Washington Post . Archived from the original on March 24, 2016. Retrieved July 24, 2019.
  53. ↑ "West Virginia Supreme Court upholds 'right-to-work' law". AP NEWS. April 21, 2020. Retrieved May 1, 2020.
  54. ↑ "Right to Work States: Guam | National Right to Work Legal Defense Foundation". Nrtw.org. May 15, 2000. Retrieved May 2, 2015.
  55. ↑ "Ohio Right to Work Laws". Although Ohio is part of America's "Rust Belt," with a long history of labor organizations, the state has adopted a very limited right-to-work law. Specifically, the law states that union membership or non-membership employment conditions are "contrary to public policy and void." So employees are not required to join a union.
  56. ↑ Overturf, Madeleine (January 16, 2018). "City of Seaford Formally Announces "Right to Work" Ordinance". WBOC-TV . Retrieved March 30, 2019.
  57. ↑ Goss, Scott (November 17, 2017). "Delaware AG: Sussex cannot approve right-to-work law". Delaware Online . The News Journal . Retrieved April 12, 2024.
  58. ↑ Goss, Scott (June 22, 2018). "Delaware Legislature passes bill to kill right-to-work in Sussex County". Delaware Online. The News Journal. Retrieved April 12, 2024.
  59. ↑ "Appeals court decision favors labor". Chicago Sun-Times. September 30, 2018. Retrieved March 30, 2019.
  60. ↑ "Docket for 18-1070". Supreme Court of the United States. Retrieved November 25, 2019.
  61. ↑ "820 ILCS 12/ Collective Bargaining Freedom Act". Illinois General Assembly. Retrieved November 25, 2019.
  62. ↑ Petrella, Dan. "In yet another rebuke to his Republican predecessor, Gov. J.B. Pritzker signs bill banning local 'right-to-work' zones". Chicago Tribune. Retrieved February 5, 2020.
  63. ↑ O'Connor, John (November 16, 2022). "Illinois voters approve collective bargaining amendment". SF Gate. Associated Press. Retrieved November 18, 2022.
  64. ↑ Bradner, Eric (November 26, 2011). "The past is present in Right to Work debate". Evansville Courier & Press . Archived from the original on November 28, 2011. Retrieved May 17, 2019.
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  66. ↑ "Michigan passes 'right-to-work' legislation". BBC News. December 11, 2012.
  67. ↑ "Whitmer repeals right-to-work, reinstates prevailing wage in Michigan". Detroit Free Press. Retrieved March 24, 2023.
  68. ↑ "Labor Gains Victory as Missouri Voters Reject Anti-Union Law". August 7, 2018. Retrieved August 7, 2018.
  69. ↑ Kevin S. Held (August 7, 2018). "Right-to-work overturned as Prop A fails". KTVI . Retrieved October 1, 2018.
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  73. ↑ "Right to work fails in NH House, 200-177". Concord Monitor. February 16, 2017. Retrieved October 14, 2020.
  74. ↑ "NH House rejects, buries right-to-work bill on key roll call of 199-175". WMUR. June 3, 2021. Retrieved June 3, 2021.
  75. ↑ "New right-to-work tactic: One piece at time". April 25, 2018. Retrieved November 17, 2018.
  76. ↑ Goth, Brenna (September 20, 2018). "Local Right-to-Work Rules Sweep New Mexico Counties". www.bna.com. Archived from the original on September 20, 2018. Retrieved March 30, 2019.
  77. ↑ Chief, Dan Boyd | Journal Capitol Bureau (January 30, 2019). "Bill would ban local 'right-to-work' laws". www.abqjournal.com. Retrieved March 30, 2019.
  78. ↑ "AFP-NM: Hang Ten". Americans for Prosperity. January 22, 2019. Retrieved March 30, 2019.
  79. ↑ "AFP: McKinley Moves on Right-to-Work". Americans for Prosperity. January 4, 2019. Retrieved March 30, 2019.
  80. ↑ "Lujan Grisham signs bill invalidating counties' right-to-work laws". March 28, 2019. Retrieved March 29, 2019.
  81. ↑ The Stunning Workers' Victory in New Mexico That You Haven't Heard About, The SE Times, December 22, 2020
  82. ↑ Community Workforce Agreement Passed in New Mexico’s Largest County; ABC Advocates Repeal Associated Builders and Contractors, September 23, 2020
  83. ↑ Albuquerque Code of Ordinances §5-5-11 (H) Project Labor Agreements, Retrieved April 4, 2022

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