Central State University v. American Association Of University Professors

526 U.S. 124 (1999)

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Nature of the Case

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Facts

The State of Ohio enacted Ohio Rev. Code Ann. § 3345.45 (1993). It passed the law in an effort to address the decline in the amount of time that public university professors devoted to teaching as opposed to researching. As part of the law, it held that the policies adopted under this section are not appropriate subjects for collective bargaining. D adopted a workload policy pursuant and notified P, the certified collective-bargaining agent for D's professors, that it would not bargain over the issue of faculty workload. P filed a complaint in Ohio state court for declaratory and injunctive relief, alleging that § 3345.45 created a class of public employees not entitled to bargain regarding their workload and that this classification violated the Equal Protection Clauses of the Ohio and United States Constitutions. The Ohio Supreme Court agreed with P that § 3345.45 deprived public university professors the equal protection of the laws. The court held that § 3345's collective-bargaining exemption bore no rational relationship to the State's interest in correcting the imbalance between research and teaching at its public universities. The Ohio Supreme Court held that 'there is not a shred of evidence in the entire record which links collective bargaining with the decline in teaching over the last decade, or in any way purports to establish that collective bargaining contributed in the slightest to the lost faculty time devoted to undergraduate teaching.' The court held that D had failed to show 'any rational basis for singling out university faculty members as the only public employees . . . precluded from bargaining over their workload.' The dissent concluded that imposing uniform workload standards via the exemption 'is not an irrational means of effecting an increase in teaching activity. In fact, it was probably the most direct means of accomplishing that objective available to the General Assembly.' The Supreme Court granted certiorari.