Central State Univ. v. Amer. Assn. Of Univ. Professors, 526 U.S. 124 (1999)

Central State University v. American


Association of University Professors
No. 98-1071


Decided March 22, 1999
526 U.S. 124

CERTIORARI TO THE SUPREME COURT OF OHIO

Syllabus

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, 319-321. 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 led 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.