Ohio Adjutant General’s Dept. v. FLRA
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Ohio Adjutant General’s Dept. v. FLRA and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Ohio Adjutant General’s Dept. v. FLRA.
The Supreme Court addressed whether the Ohio National Guard acts as a federal agency under the Federal Service Labor-Management Relations Statute (FSLMRS) when employing dual-status technicians. The Court affirmed that the FLRA has jurisdiction over the Guard, as it acts under federal authority. The decision confirms that dual-status technicians have collective bargaining rights under the FSLMRS.
Holding
The single most important “bottom line” of what the Court decided in Ohio Adjutant General’s Dept. v. FLRA.
The Court held that the FLRA had jurisdiction over the labor dispute because the Ohio National Guard acts as a federal agency under the FSLMRS when hiring and supervising dual-status technicians.
Constitutional Concepts
These are the Constitution-related themes that appear in Ohio Adjutant General’s Dept. v. FLRA. Click a concept to see other cases that involve the same idea.
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Why State–Federal Power is relevant to Ohio Adjutant General’s Dept. v. FLRA
The case involves the allocation of authority between state and federal governments, specifically whether the Ohio National Guard acts as a federal agency under the FSLMRS.
Syllabus excerpt (verbatim)The FLRA had jurisdiction over this labor dispute because a State National Guard acts as a federal agency for purposes of the FSLMRS when it hires and supervises dual-status technicians serving in their civilian role.
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Why Administrative Law is relevant to Ohio Adjutant General’s Dept. v. FLRA
The case addresses the constitutional limits on agency authority, specifically the FLRA's jurisdiction over state entities acting under federal authority.
Syllabus excerpt (verbatim)The statutory authority permitting the Ohio Adjutant General to employ dual-status technicians as civilian employees in the federal civil service reinforces this point.
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Why Preemption is relevant to Ohio Adjutant General’s Dept. v. FLRA
The case involves federal law overriding state law, as the federal FSLMRS governs labor relations involving the Ohio National Guard.
Syllabus excerpt (verbatim)The evolution of federal agency-employee relations law and the text of § 7135(b) lend further support to the FLRA's exercise of authority over the Guard.
Key Quotes
Short excerpts from the syllabus in Ohio Adjutant General’s Dept. v. FLRA that support the summary and concepts above.
The FLRA had jurisdiction over this labor dispute because a State National Guard acts as a federal agency for purposes of the FSLMRS.
Dual-status technicians are ultimately employees of the Secretaries of the Army and the Air Force.
The statutory authority permitting the Ohio Adjutant General to employ dual-status technicians as civilian employees in the federal civil service reinforces this point.
