Central State University v. American Association of University Professors

An Ohio statute required the state’s public universities to set standards for their professors’ instructional workloads and exempt those standards from collective bargaining. The state enacted the statute to ensure uniformity in professors’ workloads at universities across the state after noticing a decline in the amount of time that professors were spending teaching undergraduate students. The state believed that collective bargaining created variations in the workload requirements for faculty in similar academic departments at different universities. In 1994, Central State University (defendant) adopted a faculty-workload policy in accordance with the statute and notified its professors’ collective-bargaining agent, the American Association of University Professors (plaintiff), that the university would not be bargaining on the issue of the professors’ workloads. The association sued the university in Ohio state court, seeking a declaration that the Ohio statute violated the Equal Protection Clauses of the Ohio and United States Constitutions by creating a class of public employees who were not entitled to bargain over their workload. The Ohio Supreme Court held that the statute was unconstitutional. The court recognized that the state had a legitimate purpose for enacting the statute but held that the statute’s collective-bargaining exemption was not rationally related to the state’s interest in addressing the decline in undergraduate teaching activity. The court said that nothing in the record linked collective bargaining with the lost teaching time, and accordingly, that the state had no rational basis for treating university professors differently from all other public employees by preventingthem from bargaining over their workload. The university petitioned the United States Supreme Court for a writ of certiorari.