# Public Employment Labor Relations Act *Minnesota statute codified at Minn. Stat. ch. 179A, paired in the project record with the State's affirmative-action statute, Minn. Stat. § 43A.191.* The **Public Employment Labor Relations Act** (PELRA) is chapter 179A of the Minnesota Statutes, published by the [[Revisor of Statutes]].[^1] The project's validated claim-to-link pairs list it as a "public-union codification that interacts with §43A.191 layoffs." The pairing is filed under the project's theory of Title VII disparate treatment and [[Minn. Stat. § 43A.191]].[^1] The statute paired with PELRA is the subject of a federal suit. On January 14, 2026, the [[United States Department of Justice]] filed [[United States v. State of Minnesota (0:26-cv-00273)]] in the District of Minnesota under Title VII of the [[Civil Rights Act of 1964]]. The complaint cites § 43A.191 eight times.[^2] The Department announced the filing in release No. 26-21, titled *United States Department of Justice Files Lawsuit Against Minnesota's "Affirmative Action" Regime*.[^3] The record carries no ruling or later docket entry in the case.[^2] The record does not carry the text, enactment history or amendment history of chapter 179A. It also lacks any document setting out how the chapter's provisions operate on § 43A.191. The interaction is therefore stated here as the project's claim, not as an established legal relationship.[^1] ## What The validated claim row identifies PELRA only by its chapter citation and its pairing with § 43A.191 layoffs.[^1] A project research dossier dated September 1, 2026, describes chapter 179A as "the arbitration and exclusive-representation architecture under which discipline reversals operate." The dossier's citation for the chapter carries no validation grade. The description is the dossier's own and is not the finding of any court or agency.[^4] The dossier also logs the chapter in its matrix as coverage gap G1. That entry records the dossier's position that no live federal instrument currently reaches reinstatement through arbitration.[^4] The record carries no arbitration award, reinstatement count or discipline figure under chapter 179A. It therefore does not establish how often, or in which cases, procedures under the chapter have reversed discipline.[^1] ## Who The record does not name the legislature, governor or party that enacted chapter 179A or any later amendment. Because of that gap, the instrument cannot be attributed here by party and date.[^1] The Department of Justice brought the complaint against the State. According to release No. 26-21, Attorney General Pamela Bondi certified the case as a matter of general public importance.[^3] The release title applies the word "regime" to the State. Federal law has used that term for governments the United States opposes. The [[Iraq Liberation Act]] of 1998 (Pub. L. 105-338) states a policy of supporting efforts to remove "the regime headed by Saddam Hussein."[^5] The project's catalogue of U.S.-government "regime" usages ([[How Minnesota Got Here]], note 40) finds Minnesota the only U.S. state so described. This is the project's catalogue finding, not an independently established fact.[^5] A Time Table row citing a Wikipedia biography dates Bob Kroll's election as president of the Police Officers Federation of [[Minneapolis]] to August 2016. The same row gives his tenure as 2015–2021, and the record does not resolve the discrepancy.[^6] The row also records three facts about the training Kroll promoted: - He promoted Dave Grossman's "warrior training" for officers. - The Minneapolis City Council later banned the training. - The union then offered the training independently.[^6] The row's analytical text states that PELRA gives the union "legal insulation from civilian oversight." That is the row author's characterization. The record carries no chapter 179A provision, ruling or finding establishing it.[^6] ## When - **1974.** Governor Wendell R. Anderson issued Executive Order No. 76, *Providing for the Establishment of an Affirmative Action Program in all State Agencies*, filed with Secretary of State Arlen I. Erdahl.[^7] The order did three things: - It superseded Executive Order No. 37 of July 28, 1972. - It implemented the Governor's Code of Fair Practices, dated September 1, 1973, and the State of Minnesota Affirmative Action Policy, dated February 22, 1974. - It listed "layoff, return from layoff" among the employment actions its program covered.[^7] The record does not connect the order to chapter 179A or state its relation to § 43A.191.[^7] - **2016, August.** Kroll was elected president of the Police Officers Federation of Minneapolis, according to the Time Table row.[^6] - **2025.** The Supreme Court decided *[[Ames v. Ohio Department of Youth Services]]*, 605 U.S. 303 (2025), on Title VII disparate treatment.[^8] - **January 14, 2026.** The United States filed No. 0:26-cv-00273 in the District of Minnesota.[^2] The Department of Justice issued release No. 26-21 the same day.[^3] ## Why The record carries no statement of purpose for chapter 179A.[^1] On the affirmative-action side of the pairing, the earliest State instrument in the record states its own purpose. Executive Order No. 76 recited that the State was "committed by Title VII of the Civil Rights Act of 1964, as amended by the Equal Employment Opportunity Act of 1972, to formulate an Affirmative Action Program."[^7] The order then directed two things: - Each department and agency was to maintain a program "to insure equal employment opportunity for all its employees and for all applicants seeking employment."[^7] - The State Director of Equal Opportunity was to report annually and recommend corrective action to overcome underutilization of minorities, women and other protected classes in state employment.[^7] Fifty-two years later, the United States invoked the same federal statute against the State. The 2026 complaint, brought under Title VII, cites § 43A.191 eight times.[^2] Among those citations is subdivision 3(c). The project's pinned summary describes that subdivision as requiring an agency to explain the reason for hiring a non-affirmative candidate.[^2] The Supreme Court's 2025 decision bears on the same federal provision. In *Ames*, the Court held that Title VII's disparate-treatment provision "draws no distinctions between majority-group plaintiffs and minority-group plaintiffs." It also rejected the Sixth Circuit's heightened "background circumstances" rule for majority-group plaintiffs.[^8] The record shows the complaint's allegations as filed. It does not show any adjudication of them.[^2] ## How many - **Eight:** the number of times the January 14, 2026, complaint cites Minn. Stat. § 43A.191, as of filing.[^2] - **Nine:** the membership of the Equal Opportunity Executive Committee created by Executive Order No. 76. The committee comprised six listed officials, chaired by the Commissioner of Administration, plus three members appointed by the governor from outside state government. The order also made the committee the board of appeals for agencies found in affirmative-action "noncompliance."[^7] ## Notes [^1]: Minnesota Office of the Revisor of Statutes, *Minnesota Statutes, chapter 179A (Public Employment Labor Relations Act)* (current) — establishes the chapter citation. Validated claim row 38 pairs the chapter with § 43A.191 layoffs under the project's Title VII disparate-treatment theory. https://www.revisor.mn.gov/statutes/cite/179A [^2]: U.S. Department of Justice, Civil Rights Division, *Complaint, United States v. State of Minnesota*, No. 0:26-cv-00273 (D. Minn. filed Jan. 14, 2026) — establishes the filing date and the Title VII basis of the suit. The complaint cites Minn. Stat. § 43A.191 eight times, including subd. 3(c). https://www.justice.gov/crt/media/1423361/dl [^3]: U.S. Department of Justice, Office of Public Affairs, *United States Department of Justice Files Lawsuit Against Minnesota's "Affirmative Action" Regime*, release No. 26-21 (Jan. 14, 2026) — establishes the release title and Attorney General Bondi's certification of general public importance. https://www.justice.gov/opa/pr/united-states-department-justice-files-lawsuit-against-minnesotas-affirmative-action-regime [^4]: Minnesota Office of the Revisor of Statutes, *Minnesota Statutes, chapter 179A*, as cited in project dossier *Halloween Capital 5000 STEELMAN* (Sept. 1, 2026), note 21 — the dossier's description of the chapter and its coverage-gap entry G1. The source is ungraded ("?") and the description is not validated. https://www.revisor.mn.gov/statutes/cite/179A [^5]: United States Congress, *Iraq Liberation Act of 1998*, Pub. L. 105-338 (1998) — establishes the policy of supporting efforts to remove "the regime headed by Saddam Hussein." Cited in pinned claim PIN-03 alongside the project's catalogue finding (How Minnesota Got Here, note 40). https://www.govinfo.gov/content/pkg/PLAW-105publ338/pdf/PLAW-105publ338.pdf [^6]: Wikipedia, *Bob Kroll (police officer)*, as cited in Time Table row TL-0854 (Aug. 2016) — Kroll's election and tenure dates, the warrior-training entries, and the row's analytical text on PELRA. Secondary source. https://en.wikipedia.org/wiki/Bob_Kroll_(police_officer [^7]: Office of the Governor of Minnesota, *Executive Order No. 76: Providing for the Establishment of an Affirmative Action Program in all State Agencies* (1974), archived by the Minnesota Legislative Reference Library — establishes the order's recitals, scope, committee and supersession. https://www.lrl.mn.gov/archive/execorders/74-76.pdf [^8]: Supreme Court of the United States, *Ames v. Ohio Department of Youth Services*, 605 U.S. 303 (2025) — establishes the holding on Title VII disparate treatment and the rejection of the "background circumstances" rule. https://www.supremecourt.gov/opinions/24pdf/23-1039_c0n2.pdf