Labor and Employment Law - Quarles & Brady LLP

Reprinted with permission from the 2012 edition of Annual Survey of Wisconsin Law, (c) State Bar of Wisconsin 2012. To order the complete 

Annual Survey or for information on other PINNACLE books, contact the State Bar of Wisconsin at marketplace.wisbar.org/BooksKnowledgeProducts. 

Labor and Employment Law 

by Courtney R. Heeren 

Courtney R. Heeren is an associate with Quarles & Brady LLP, Milwaukee. She practices in the 

firm’s Labor & Employment Group, representing management with an emphasis on the defense of 

discrimination and other employment-related claims in front of administrative, state, and federal 

agencies and courts. She also focuses on day-to-day client counseling on a variety of compliance 

and human-resource issues. She is a member of the American Bar Association, the State Bar of 

Wisconsin, and the Milwaukee Young Lawyers Association, and she is a co-chair of the Association 

of Women Lawyers’ Pro Bono Committee. Ms. Heeren received her B.A. in English and French 

from the University of Wisconsin and her J.D. from Northeastern University School of Law. 

This chapter reviews significant Wisconsin judicial and statutory developments of 2011 in the area of labor and 

employment law. Wisconsin’s legislative changes to its labor and employment laws put the state in the national 

spotlight with 2011 Wisconsin Act 10 (known as the Scott Walker Budget Repair Bill) and its amendments regarding 

public employees’ collective bargaining rights. Although Act 10 dominated the labor and employment discussion 

for much of 2011, other significant legislative and judicial developments occurred during the year as well. 

Milwaukee’s paid sick leave ordinance was put into effect by the court of appeals but later preempted by state 

legislation. The court of appeals clarified overtime calculations under Wisconsin law and examined the statutes of 

limitation for filing a discrimination charge. A new concealed-carry law went into effect in November 2011, making 

Wisconsin the 49th state to allow individuals to carry concealed weapons. In addition, prevailing wage laws were 

returned to 2009 standards, and child labor laws governing hours worked were amended to parallel requirements 

under federal law. 1 

CASE LAW 

Court of Appeals Upholds Milwaukee Paid Sick Leave Ordinance 

On November 4, 2008, voters passed a referendum mandating paid sick leave for all private-sector employees 

working in the city of Milwaukee. The terms of the ordinance required that covered employers give employees 1 

hour of paid sick leave for every 30 hours worked, up to 72 hours (or nine days) of leave per calendar year. The 

ordinance required smaller employers (those with fewer than 10 employees) to provide 40 hours (or five days) of 

paid sick leave per calendar year. 

In Metropolitan Milwaukee Ass’n of Commerce v. City of Milwaukee, 2011 WI App 45, 332 Wis. 2d 459, 798 

N.W.2d 287, the court of appeals upheld the Milwaukee paid sick leave ordinance, sending the case back to the 

circuit court with an order to lift the permanent injunction that the circuit court had placed on implementation of the 

ordinance in 2010. 

The circuit court’s injunction was the result of a legal challenge brought by the Metropolitan Milwaukee Association 

of Commerce (MMAC). The MMAC had challenged the referendum on a number of grounds: (1) The ballot on 

which the referendum was listed did not comply with the statutory requirement that it be a “concise statement of [the 

ordinance’s] nature,” see Wis. Stat. § 9.20(6); (2) the ordinance violated substantive due process because there was 

not a rational relationship to the city’s police powers; (3) the ordinance was preempted by state statutes; (4) the 

ordinance was preempted by the National Labor Relations Act (NLRA) and the Labor Management Relations Act 

1 Textual references to the Wisconsin Statutes are indicated as “chapter xxx” or “section xxx.xx,” without the designation “of the 

Wisconsin Statutes.” Unless otherwise indicated, in the Statutory Developments section of this chapter, all references to the 

Wisconsin Statutes are to the 2009–10 Wisconsin Statutes, as affected by acts through 2011 Wisconsin Act 113. 

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(LMRA); (5) the ordinance violated the state and federal constitutional prohibitions against impairment of contracts; 

(6) the ordinance regulated activity outside the city limits; and (7) the statutory two-year period during which the 

ordinance may not be repealed or amended except by a vote of the electors, see Wis. Stat. § 9.20(8), began to run 

when the ordinance initially passed and continued to run even while the ordinance was enjoined. 

The court of appeals disagreed on every point raised by the MMAC, focusing on the following issues. First, the 

court found that the ballot, despite the fact that it did not list each reason for which an employee could take leave 

under the ordinance, qualified as a concise statement of the ordinance’s nature within the meaning of section 

9.20(6). MMAC, 2011 WI App 45, ¶ 44, 332 Wis. 2d 459. The court found that there had been other means for 

voters to have learned about the details of the proposed ordinance’s content, including a posting at each polling 

place, and it was not necessary for the ballot to spell out every detail. Id. ¶ 33. 

Second, the court disagreed with the MMAC that the ordinance was not a valid exercise of the city’s police powers. 

Applying the legal standard that the legislative means chosen must have a rational relationship to the purpose or 

object of the enactment and that the object must be a proper one, the court concluded that there was a reasonable 

relationship between the ordinance and a legitimate municipal objective—namely, the health, safety, and welfare of 

the city’s residents. Id. ¶¶ 49, 51, 57. The court also held that the minimum annual-sick-leave time established by 

the ordinance—72 hours (or 40 hours for small businesses)—was not unreasonable. Id. ¶ 79. 

Next, the court addressed the MMAC’s arguments that the ordinance was preempted by either state or federal law. 

The MMAC had asserted that the ordinance was preempted by three state statutes: the minimum wage law, chapter 

104; the Family or Medical Leave Act (FMLA), section 103.10; and the Worker’s Compensation Act, chapter 102. 

Id. ¶ 80. Because the minimum wage law does not consider benefits except tips, meals, and lodging, and because 

the ordinance did not increase the hourly wage rate as defined by the Department of Workforce Development 

(DWD), the court concluded that the ordinance—which only addressed additional sick leave benefits—was not 

preempted by chapter 104. Id. ¶ 83. The court also disagreed that the Wisconsin FMLA preempted the ordinance, 

finding that the ordinance and the statute did not logically conflict because the text of the Wisconsin FMLA statute 

allows for its coexistence with other forms of leave. Id. ¶ 84. Lastly, the court disagreed that the Worker’s 

Compensation Act preempted the ordinance, finding that that statute specifically allowed for overlapping benefits 

similar to those provided for in the ordinance. Id. ¶ 86. 

The court also rejected the MMAC’s argument that federal law—specifically, the NLRA and the LMRA— 

preempted the ordinance. Regarding NLRA preemption, the court found that the ordinance created minimum labor 

standards as have been carved out in NLRA case law as specifically not leading to preemption. Id. ¶ 92. Regarding 

LMRA preemption, the court found that application of the ordinance did not require interpretation of collective 

bargaining agreements since it established rights and obligations independent of labor contracts and, therefore, also 

did not lead to preemption. Id. ¶ 95. 

The court of appeals reversed the circuit court’s decision, remanding the matter with orders to grant summary 

judgment in favor of the Milwaukee chapter of the 9to5 National Association of Working Women (an intervenor 

supporting implementation of the ordinance) and to lift the permanent injunction. Id. ¶ 114. 9to5’s victory, 

however, was short-lived: Before the ordinance could go into effect, the state legislature passed a law, discussed 

below in the Statutory Developments section, completely preempting it. 

Clarifying Overtime Calculations 

The court of appeals reviewed the issue of calculating overtime under Wisconsin law in Kuhnert v. Advanced Laser 

Machining, Inc., 2011 WI App 23, 331 Wis. 2d 625, 794 N.W.2d 805 (review denied). Kuhnert had worked as an 

entry/scheduling clerk and purchasing agent for Advanced Laser and was paid on a salary basis. Id. ¶ 2. After 

Kuhnert was discharged, she filed a wage complaint with the DWD alleging that she was improperly classified as an 

overtime-exempt employee and she was entitled to recover unpaid overtime wages. Id. ¶ 3. 

Although the DWD’s Labor Standards Bureau director found in Kuhnert’s favor, finding that her position was not 

overtime exempt and that she therefore should have received overtime pay, he did not award her the amount of 

backpay to which she believed she was entitled, and Kuhnert appealed the matter to the circuit court. 

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To reach his overtime calculation, the Labor Standards Bureau director used the following method: (1) determine 

the average hourly rate of pay per pay period by dividing total regular wages received in a pay period (salary) by the 

total hours worked; (2) determine the “overtime premium rate” by dividing the “average hourly rate” by two; and 

(3) multiply the overtime premium rate for each pay period by the overtime hours worked to determine the overtime 

premium pay due. Id. ¶ 4. The Labor Standards Bureau director’s decision specifically pointed out that people 

often think of overtime pay as one and one-half times the regularly hourly rate, but he stated that is an error. Id. He 

observed that it is actually the “regular rate” plus the overtime premium rate. Id. 

Kuhnert used a different method for calculating overtime, which she claimed resulted in her being owed 

approximately $12,000, in contrast with the $2,699.25 in overtime pay that she would be owed according to the 

DWD’s calculation. Id. ¶ 1. She argued that the DWD should have calculated her overtime pay by (1) dividing her 

normal weekly salary by the number of hours she was expected to work per week to determine her regular rate of 

pay; (2) multiplying the regular rate of pay by 1.5 to determine her overtime rate; and (3) multiplying the overtime 

rate by the number of overtime hours worked each week. Id. ¶ 5. 

The court of appeals gave great-weight deference to the DWD’s calculation and affirmed its decision. The court of 

appeals acknowledged that the relevant statutory and administrative text—section 103.025(1)(c) and Wisconsin 

Administrative Code section DWD 274.03—required that a nonexempt employee be compensated for overtime 

hours at a rate of one and one-half times the regular rate of pay. But the court also observed that the statutes and 

administrative code left the regular rate of pay and the method for calculating it undefined. The DWD had 

developed a method to determine overtime pay for a nonexempt salaried employee, id. ¶ 14 (citing DWD 

publication ERD-13109-P), and the court determined that this method was consistent with the requirements of the 

Wisconsin Statutes and the Wisconsin Administrative Code, with the supreme court’s approach for calculating 

overtime wages, and with the DWD’s long-standing practice. Id. ¶¶ 14–18. Based on this analysis, the court 

concluded that the DWD’s interpretation was a reasonable one. 

Clarifying the 300-Day Statutes of Limitation for Filing a Discrimination Charge 

In Aldrich v. LIRC, 2011 WI App 94, 334 Wis. 2d 495, 801 N.W.2d 457 (review granted), the court of appeals 

examined the 300-day statutes of limitation applicable to filing discrimination charges with the U.S. Equal 

Employment Opportunity Commission (EEOC) and the Wisconsin Equal Rights Division (ERD) and addressed 

whether a plaintiff could relitigate the timeliness of a charge under the Wisconsin Fair Employment Act (WFEA) 

when the timeliness under federal law had already been litigated. The relevant statutes of limitation can be found at 

42 U.S.C. § 2000e-5(e)(1) and section 111.39(1). 

Joyce Aldrich had signed a Charge Questionnaire with the EEOC on August 27, 2003. She had been demoted from 

her position at Best Buy in March 2003. Id. ¶ 4. According to Aldrich, she understood her charge to have been filed 

when she signed the questionnaire. Id. The EEOC investigator notified Aldrich two days after she had signed the 

questionnaire that it was necessary to speak with her to obtain all the information the investigator needed to draft the 

charge, requesting that Aldrich contact the investigator within five days after receiving the investigator’s letter. Id. 

Aldrich later did have contacts with EEOC investigators and signed a charge of age and sex discrimination, which 

the EEOC received on February 10, 2004, more than 300 days after the demotion at issue. Id. ¶ 5. Pursuant to a 

work-sharing agreement between the EEOC and the ERD, the ERD received the charge on February 18, 2004. Id. 

Following an investigation, the EEOC dismissed Aldrich’s claims, and Aldrich filed a federal action, alleging sex 

and age discrimination, as well as constructive discharge. Id. ¶ 6. Best Buy successfully won a motion to dismiss 

on the basis that Aldrich’s charge had not been timely filed and that her charge, although it included allegations 

regarding her demotion, did not include any allegations regarding her subsequent discharge. Id. Aldrich did not 

appeal the dismissal. Id. 

Instead, Aldrich requested that the ERD independently investigate the charge. Id. ¶ 7. Following its investigation, 

the ERD found that there was probable cause to believe that Aldrich had been discriminated against. Id. However, 

during the subsequent hearing, the administrative law judge (ALJ) granted Best Buy’s motion to dismiss on the 

ground of claim preclusion—namely, that Aldrich had already litigated this claim in federal court. Id. Although the 

Labor and Industry Review Commission (LIRC) affirmed the ALJ’s dismissal, the circuit court reversed. The court 

of appeals affirmed the circuit court, finding that the doctrine of claim preclusion did not apply to Aldrich’s claims 




because Aldrich had not been able to bring her claims under Wisconsin’s specific antidiscrimination statute—the 

WFEA—in the prior federal action. Id. On remand to the ERD, Best Buy again moved to dismiss, this time on 

grounds that Aldrich’s demotion claims were time-barred because the federal court had found her EEOC charge 

untimely and, therefore, her complaint filed with the ERD was also untimely. Id. ¶ 8. Best Buy maintained that 

issue preclusion barred reconsideration of the issue of timeliness because it had already been litigated in the federal 

action. Id. The ALJ granted the motion, and LIRC affirmed, but the circuit court again vacated LIRC’s decision. 

Id. 

Following Best Buy’s appeal, the court of appeals affirmed LIRC’s finding that issue preclusion prevented such 

relitigation. Id. ¶ 1. The court of appeals found that Aldrich was not entitled to an independent review by a state 

court of whether the questionnaire she signed with the EEOC constituted a complaint within the meaning of 

Wisconsin Administrative Code section DWD 218.03(3). The court reasoned that the EEOC questionnaire was 

never physically received by the ERD and was therefore never “filed” with the ERD, much less filed within the 

requisite 300 days under section 111.39(1). Id. ¶ 13. The court further found that there was no provision for an 

independent state law analysis of whether such earlier-filed documents with the EEOC might satisfy the complaint 

requirement. Id. ¶ 15. 

The court of appeals also declined to allow for independent review of the timeliness of the charge itself. The court 

concluded that, by providing a mechanism to determine a single date for filing of cross-filed complaints, as well as a 

single analysis for compliance with the complaint requirement, the DWD precluded the possibility that a 

complainant could twice litigate a statute-of-limitation claim. Id. ¶ 16. The court found that the language of 

Wisconsin Administrative Code section DWD 218.03(5) “makes the date of filing with the EEOC dispositive for 

purposes of a cross-filed claim with the WFEA.” Id. ¶ 19. Because the correct EEOC filing date had already been 

litigated and fundamental fairness did not require otherwise, the court of appeals concluded that the application of 

issue preclusion was appropriate. Id. ¶ 22. 

STATUTORY DEVELOPMENTS 

Public Employees’ Collective Bargaining Rights Significantly Narrowed 

On March 11, 2011, Governor Scott Walker signed into law what is known as the Scott Walker Budget Repair Bill 

or Act 10. See 2011 Wis. Act 10. Among other amendments governing the compensation and fringe benefits of 

public employees, the act significantly limited the collective bargaining rights of certain public employees. 

Introduced on February 15, 2011, in the Wisconsin Assembly’s Committee on Assembly Organization as January 

2011 Special Session Assembly Bill 11 at the request of Governor Walker, the bill initially required additional 

public employee contributions for health care and pensions, curtailed collective bargaining rights for most state and 

local public employees, and made appropriations. Because the bill contained appropriations, three-fifths of all 

members of each legislative house were required to be present for any vote on the passage to constitute a quorum. 

Wis. Const. art. VIII, § 8. Following its introduction, the bill was referred to the Joint Finance Committee, where it 

was amended and calendared for debate in the assembly on February 17, 2011. According to the bill’s paper 

history, it was debated for approximately 61 consecutive hours. Following amendment and approval in the 

assembly, the bill was passed to the Wisconsin State Senate on February 25, 2011. However, the senate, after 

reading the bill three times, could not proceed because it lacked a quorum. All 14 Democratic senators had absented 

themselves from the senate chambers before the senate’s consideration of the bill began—those senators left the 

state and did not appear publicly again in Madison until March 12, 2011. 

On March 9, 2011, a Joint Committee of Conference was created, and it amended the bill to remove the bill’s fiscal 

aspects so that three-fifths of each legislative house (i.e., 20 members in the senate) no longer needed to be present 

to pass the bill. The senate then approved the bill by a vote of 18–1 with no debate. On March 10, 2011, the 

assembly passed the bill by a vote of 53–42. 

A summary of the main aspects of Act 10 pertaining to the area of labor and employment is as follows. The 

provision of Act 10 that drew the most attention deals with the overall collective bargaining rights of public 

employees. Before passage of Act 10, municipal and state employees had the right to collectively bargain over 



Annual Survey of Wisconsin Law Labor and Employment Law 

wages, hours, and conditions of employment under the Municipal Employment Relations Act (MERA, see Wis. 

Stat. §§ 111.70–.77) and the State Employment Labor Relations Act (SELRA, see Wis. Stat. §§ 111.81–.94). Act 10 

amended MERA and SELRA with respect to all employees except certain public safety employees. Other than 

those excepted employees, public employees are limited to collectively bargain over base wages and, unless a 

referendum authorizes a larger increase, that percentage increase can be no greater than the percentage change in the 

consumer price index. 

Act 10 also prohibits salary deductions for labor organization dues except for public safety employees and 

eliminates the ability of employees of the University of Wisconsin (UW) System, UW Hospitals and Clinics 

Authority, and certain home-care and child-care providers to collectively bargain over wages, hours, and conditions 

of employment. 

Act 10 also limits the terms of collective bargaining agreements and their ability to be extended. Specifically, 

before the Act 10 amendments, the term of collective bargaining agreements—other than initial collective 

bargaining agreements—was generally two years for state and municipal employees. Also, before Act 10, collective 

bargaining agreements could be extended. After Act 10, the term of collective bargaining agreements is limited to 

one year and extensions are prohibited. 

Although Act 10 was enjoined by the Dane County Circuit Court (State ex rel. Ozanne v. Fitzgerald, No. 11CV1244 

(Wis. Cir. Ct. Dane Cnty. Mar. 18, 2011)), the Wisconsin Supreme Court vacated the order to enjoin implementation 

of Act 10 in State ex rel. Ozanne v. v. Fitzgerald, 2011 WI 43, 334 Wis. 2d 70, 798 N.W.2d 436, and the act was 

republished on June 28, 2011, and took effect on June 29, 2011. 

Paid Sick Leave Preempted by State Law 

As discussed above, the court of appeals revived Milwaukee’s paid sick leave ordinance on March 24, 2011, when it 

reversed the circuit court and remanded the matter with an order to grant summary judgment in favor of the 

intervenor supporting implementation of the ordinance and to lift the permanent injunction on the ordinance. 

Metropolitan Milwaukee Ass’n of Commerce v. City of Milwaukee, 2011 WI App 45, 332 Wis. 2d 459, 798 N.W.2d 

287. However, the impending implementation of the ordinance was short-lived. While the appeal was pending, 

both the Wisconsin Senate and the Wisconsin Assembly introduced companion bills to nullify the ordinance. Both 

houses ultimately passed the legislation, and Governor Walker signed it into law as 2011 Wisconsin Act 16, 

effective May 20, 2011. Act 16 provided that because family and medical leave is a statewide concern regarding 

which there should be consistency throughout the state, local governments could not enact local ordinances (such as 

the Milwaukee paid sick leave ordinance) requiring employers to provide paid or nonpaid leave for the reasons 

outlined in the act. See Wis. Stat. § 103.10(1m), as created by 2011 Wis. Act 16. Act 16 also specifically 

preempted any such ordinance (such as the Milwaukee paid sick leave ordinance) in place on the statute’s effective 

date. See Wis. Stat. § 103.10(1m)(e). 

Concealed-Carry Law Goes into Effect 

Effective November 1, 2011, Wisconsin became the 49th state to allow individuals to carry concealed weapons. 

The new law (2011 Wis. Act 35), which applies to all employers regardless of size, affects whether and how 

employers can prohibit weapons at work and on their property. Under the new legislation, residents 21 years and 

older are allowed to carry a concealed weapon anywhere in the state, with only a few limited exceptions. Concealed 

weapons are still banned in schools, police stations, sheriff’s offices, prisons, jails, courthouses, and airports (but 

only beyond security checkpoints). Wis. Stat. § 175.60(16), as created by 2011 Wis. Act 35; see also Wis. Stat. 

§ 948.605(2) (gun-free school zones), as affected by 2011 Wis. Act 35. 

Under the new law, employers are still allowed to prohibit employees from carrying weapons (concealed or 

otherwise) while at work, both at the employer’s place of business and if the employee works off-site. However, 

employers can no longer prohibit employees from carrying or storing a weapon in the employee’s own motor 

vehicle. If an employer does choose to allow its employees to carry concealed weapons at work, the new law gives 

the employer immunity from lawsuits for any liability arising from that policy decision. Wis. Stat. § 175.60(21), as 

created by 2011 Wis. Act 35. 




Revised 2010 Prevailing Wage Law Repealed 

Effective January 1, 2010, the 2009 state budget act, see 2009 Wis. Act 28, had expanded the reach of Wisconsin’s 

prevailing wage laws (amending sections 66.0903, 103.49, and 103.50) so that public construction projects were 

subject to prevailing wage requirements if total completion costs (labor, equipment, and materials) exceeded 

$25,000 for both single-trade and multi-trade projects. A single-trade project of public works means a project in 

which a single trade accounts for at least 85% of the total labor costs of the threshold. Wis. Stat. § 103.49(1)(em), 

as created by 2011 Wis. Act 32, § 2390d; see also Wis. Stat. § 103.49(1)(e) (2007–08), repealed by 2009 Wis. Act 

28, § 2188. A multiple-trade project of public works means a project in which no single trade accounts for at least 

85% of the total labor cost of the project. Wis. Stat. § 103.49(1)(br), as created by 2011 Wis. Act 32, § 2390c; see 

also Wis. Stat. § 103.49(1)(bm) (2007–08), repealed by 2009 Wis. Act 28, § 2187. The 2009 budget act had 

lowered the cost-of-completion thresholds from $234,000 for multiple-trade projects and $48,000 for single-trade 

projects. See Wis. Stat. §§ 66.0903(5), 103.49(3g) (2007–08); Wis. Admin. Code § DWD 290.155(1) (June 2009). 

The 2011–13 Budget Bill, 2011 Wisconsin Act 32, repealed the prevailing-wage-law-related provisions of the 2009 

budget act, amending the prevailing wage law to the thresholds of $100,000 for a multiple-trade project of public 

works, $234,000 for a multiple-trade project of public works for a city or village with a population of less than 2,500 

or a town, and $48,000 for a single-trade project of public works. Wis. Stat. §§ 66.0903(5)(a), 103.49(3g)(a), as 

amended by 2011 Wis. Act 32, §§ 1727n, 2390m. As a result, the now repealed thresholds established by 2009 

Wisconsin Act 28 apply only to projects that awarded the prime contract during the effective period of the 2009 

Wisconsin Act 28 amendments—namely, January 1, 2010 through June 30, 2011. The revised thresholds, provided 

under 2011 Wisconsin Act 32, went into effect on July 1, 2011. Other significant changes included the repeal of the 

requirement that every contractor on a prevailing wage project submit a monthly certified record to the DWD on its 

website. Wis. Stat. §§ 66.0903(10)(am), 66.0904(8)(am), 103.49(5)(am) (2009–10), repealed by 2011 Wis. Act 32, 

§§ 1727t, 1727y, 2390s. 

Child Labor Laws 

The legislature amended Wisconsin’s child-labor hours’ limitations to align them with federal law. Under the 

revised law, 

1. Minors 16 years of age and over may not work during hours of required school attendance. Other than this 

requirement, the law no longer limits either the daily or weekly work hours of minors who are 16 years or older 

or the time of day that they may work. 

2. Minors under the age of 16 are limited to working (year-round) no more than three hours per day on school days 

and no more than eight hours per day on nonschool days. 

3. Minors under the age of 16 may work no longer than 18 hours in a school week, and their workday from the day 

after Labor Day through May 31 must be between the hours of 7:00 a.m. and 7:00 p.m. 

4. Minors under the age of 16 may work no longer than 40 hours in a nonschool week, and their workday from 

June 1 through Labor Day must be between the hours of 7:00 a.m. and 9:00 p.m. 

Wis. Stat. § 103.68, as affected by 2011 Wis. Act 32, §§ 2390zm, 2390zn, 2390zp.

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