University Education Association v. Regents of the University of Minnesota
Minnesota Supreme Court
353 N.W.2d 534 (1984)
- Written by Jennifer Flinn, JD
Facts
The University of Minnesota was a public university governed by its board of regents (the regents) (defendant). The University Education Association and the Minnesota Education Association (the associations) (plaintiffs) were the certified exclusive bargaining organizations for university faculty. The Minnesota Public Employment Labor Relations Act (PELRA) required public employers, such as the university, to negotiate in good faith with the collective-bargaining representative of their employees. Specifically, PELRA required public employers to negotiate regarding employee-grievance procedures and their terms and conditions of employment but did not require negotiation on matters of inherent managerial policy. The regents met with the associations on multiple occasions to negotiate a collective-bargaining agreement. Though the regents and associations were able to reach an agreement on most issues, three issues remained on which the regents refused to negotiate: (1) criteria surrounding faculty promotion and tenure, (2) criteria regarding faculty evaluations, and (3) issues relating to the academic calendar. The regents argued that these three issues were inherent managerial policies related to the academic reputation and integrity of the university that the regents were not required to negotiate. The associations filed a lawsuit, accusing the regents of unfair labor practices for refusing to negotiate. The trial court granted summary judgment in favor of the regents. The associations appealed.
Rule of Law
Issue
Holding and Reasoning (Amdahl, C.J.)
Dissent (Yetka, J.)
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