Minnesota State Board for Community Colleges v. Knight

Minnesota had a law requiring public employers to engage in official exchanges of views with employees on employment-related policy matters that fell outside the scope of mandatory bargaining. However, under this law, if there existed an official representative for public employees, this exchange could only take place with that official representative. Essentially, public employees could not meet and confer or meet and negotiate outside of the official representative. The Minnesota State Board for Community Colleges (the board) (defendant) operated the Minnesota community college system. The Minnesota Community College Faculty Association (the union) (defendant) represented faculty of the state’s community colleges. At the state level, the union and board held meetings and conferred to discuss systemic issues. At the campus level, the union and board established meetings to discuss campus-specific questions. These meetings operated as the Minnesota College Administration. Leon Knight and other community college faculty instructors unaffiliated with the faculty union (collectively, Knight) (plaintiffs) filed suit in federal district court, contending that the limitation on exchanges of views to an official representative violated the constitutional rights of professional employees who were not members of the group represented by the official representative. The district court found that the state law violated the First and Fourteenth Amendments of speech and association for employees who were not members of the union. Knight, the board, and the union all filed an appeal to the Supreme Court.