Pennsylvania General Assembly's Authority to Enact Laws Subjecting Collective Bargaining Agreements

In Wilkinsburg Police Officers Association v. Commonwealth, 535 Pa. 425, 636 A.2d 134 (1993), the Supreme Court noted that Article III, 31 of the Pennsylvania Constitution empowers the General Assembly to enact laws "subjecting collective bargaining agreements with policemen and firemen to binding arbitration." 535 Pa. at 435, 636 A.2d at 139. Because the Constitution does not mandate the enactment of laws on the subject, the Court opined that "even if section 252 of Act 47 operates as a bar to prospective bargaining agreements or arbitration awards ... it would not violate Article III, Section 31 ... ." Id. The Supreme Court therein recognized the notion that those rights that the General Assembly grants concerning collective bargaining and arbitration, the General Assembly may also limit or take away.