Central State Univ. v. American Assn. of Univ. Professors, Central State Univ. Chapter
Annotate this Case
526 U.S. 124 (1999)
OCTOBER TERM, 1998
CENTRAL STATE UNIVERSITY v. AMERICAN ASSOCIATION OF UNIVERSITY PROFESSORS, CENTRAL STATE UNIVERSITY CHAPTER
ON PETITION FOR WRIT OF CERTIORARI TO THE SUPREME COURT OF OHIO
No. 98-1071. Decided March 22, 1999
Pursuant to Ohio Rev. Code Ann. § 3345.45, petitioner university adopted standards for its professors' instructional workloads and notified respondent, the certified collective-bargaining agent for the professors, that it would not bargain over the workload issue. Respondent then filed a complaint in state court for declaratory and injunctive relief, alleging that § 3345.45 created a class of public employees not entitled to bargain regarding their workload in violation of the Equal Protection Clauses of the Ohio and United States Constitutions. The Ohio Supreme Court held that the collective-bargaining exemption bore no rational relationship to the State's interest in correcting the imbalance between research and teaching at its public universities, and concluded that the State had not shown any rational basis for singling out university professors as the only public employees precluded from bargaining over their workload.
Held: The Ohio Supreme Court's holding cannot be reconciled with the requirements of the Equal Protection Clause. This Court has repeatedly held that where a classification involves neither fundamental rights nor suspect proceedings it cannot run afoul of the Clause if there is a rational relationship between disparity of treatment and some legitimate governmental purpose. E. g., Heller v. Doe, 509 U. S. 312, 319321. The legislative classification here passes that test. Imposing a workload policy not subject to collective bargaining was an entirely rational step to accomplish the statute's objective of increasing the time faculty spent in the classroom. The fact that the record before the Ohio courts did not show that collective bargaining had lead to the decline in faculty classroom time does not detract from the legislative decision's rationality.
Certiorari granted; 83 Ohio St. 3d 229, 699 N. E. 2d 463, reversed and remanded.
Petitioner Central State University challenges a ruling of the Ohio Supreme Court striking down on equal protection grounds a state law requiring public universities to develop standards for professors' instructional workloads and exempting those standards from collective bargaining. We grant the petition and reverse the judgment of the Ohio Supreme Court.
In an effort to address the decline in the amount of time that public university professors devoted to teaching as opposed to researching, the State of Ohio enacted Ohio Rev. Code Ann. § 3345.45 (1997). This provision provides in relevant part:
"On or before January 1, 1994, the Ohio board of regents jointly with all state universities ... shall develop standards for instructional workloads for full-time and part-time faculty in keeping with the universities' missions and with special emphasis on the undergraduate learning experience ....
"On or before June 30, 1994, the board of trustees of each state university shall take formal action to adopt a faculty workload policy consistent with the standards developed under this section. Notwithstanding [other provisions making faculty workload at public universities a proper subject for collective bargaining], the policies adopted under this section are not appropriate subjects for collective bargaining. Notwithstanding [these collective-bargaining provisions], any policy adopted under this section by a board of trustees prevails over any conflicting provisions of any collective bargaining agreement between an employees organization and that board of trustees."*
* As part of the same bill codified at § 3345, the Ohio General Assembly also enacted uncodified legislation providing that the Board of Regents