Statutory Employee Representation in Italian and U.S. Workplaces : A Comparative Analysis of the Fiat/Chrysler Case

Italian and the U.S. rules relating to workplace employee representation are radically different, as they originated in diverse historical and social contexts. In this sense, the Fiat-Chrysler case marks a paradigmatic example of the issues arising from the attempt of a global employer to set the same working conditions throughout the whole group, notwithstanding the different legal framework in the countries where its national branches (Fiat and Chrysler) are located. Fiat had to counter the harsh opposition of one of the main Italian unions, which led to several disputes and, ultimately, to the amendment of the Italian law provisions on employee representation by the Constitutional Court. Chrysler's employees had to accept severe cuts in their salary and the other significant concessions agreed by their exclusive union representative (UAW), as the only alternative to company liquidation. While comparing the rules in the matter of union representation in the two countries, the author examines labor law reform proposals in both countries' industrial relations systems and, more broadly, the role of unions and collective bargaining in the current era