Officer Farouqah Idris, a correctional officer employed by the Maryland Department of Public Safety and Correctional Services, served as vice president of her local union and AFSCME’s designated co-chair of the Labor-Management Committee (LMC) at Maryland Correctional Institution–Jessup. Under the parties’ Memorandum of Understanding, the union had the right to select its representatives to the LMC, and Idris had regularly organized and co-chaired meetings with management for several years.
On February 28, 2024, the day after a routine LMC meeting, the warden issued Idris an email prohibiting her from “visiting, representing, or conducting business” at the facility. No operational or security justification was provided. Despite that directive, Idris continued performing her union role and prepared for the next LMC meeting scheduled for March 26, 2024, which the warden confirmed. When Idris arrived for the meeting, however, she was denied entry while other union representatives were permitted to attend. She was ordered to leave and thereafter allowed to participate only remotely, under protest.
AFSCME and Idris filed an unfair labor practice charge alleging violations of §§ 22-206(a)(1) and (2) of Maryland’s Public Employee Relations Act (PERA). Those provisions prohibit a public employer from interfering with employees’ protected rights and from interfering with the formation or administration of an employee organization, including its ability to select its representatives.
The Public Employee Relations Board sustained the charge, finding that the Department violated PERA. The Board emphasized that employees have a statutory right to engage in union activity and that unions have a corresponding right to designate their own representatives. The governing test does not turn on employer intent but on whether the conduct “reasonably tends to interfere” with protected rights.
Applying that framework, the Board held that the Department’s exclusion of Idris from the March 26 meeting was presumptively unlawful. Idris sought only to attend a labor-management meeting in a non-inmate administrative area, and the Department presented no evidence of “special circumstances” or operational necessity justifying her exclusion. The Board rejected the Department’s reliance on prior disciplinary issues, noting that those concerns did not explain or justify barring her from participating in a routine LMC meeting.
The Board also rejected the argument that allowing Idris to participate remotely cured the violation. The right at issue belonged not only to Idris but to the union itself. By preventing its chosen co-chair from attending in person, the Department effectively interfered with AFSCME’s ability to designate and utilize its representative, which the statute protects.
Because the Department failed to demonstrate any legitimate justification for excluding Idris and thereby interfered with both employee rights and the union’s representational rights, the Board found violations of §§ 22-206(a)(1) and (2). It ordered the Department to cease and desist, post a notice, and recognize the union’s right to select its LMC representatives without interference.
AFSCME Council 3 & Officer Farouqah Idris v. Department of Public Safety and Correctional Services, PERB ULP 2024-29, 2025 WL 4347909 (Md. PERB Oct. 10, 2025).