Central State Univ. v. American Assn. of Univ. Professors, Central State Univ. Chapter

Background

Ohio passed a law requiring the State Board of Regents and public universities to set standards for professors’ instructional workloads and directing each university to adopt those policies. The law also said those workload policies were not proper subjects for collective bargaining and would override conflicting union contracts. Central State University adopted such a policy; the professors’ union sued, and the Ohio Supreme Court struck the law down on equal protection grounds, finding no record evidence linking collective bargaining to a decline in classroom teaching.

Reasoning

The U.S. Supreme Court asked whether the law’s classification was irrational. The Court, in a short per curiam opinion, concluded the legislature had a legitimate interest in increasing classroom teaching and could reasonably decide that uniform, nonbargainable workload rules would help achieve that goal. The Court applied the usual rational-basis test, held the classification was rational even without direct proof, reversed the Ohio Supreme Court, and returned the case for further steps consistent with its opinion.

Real world impact

As a practical matter, Ohio public universities may adopt and enforce workload policies without bargaining over those specific rules, at least under this decision. The case was decided summarily, so the Court noted the opinion’s precedential scope is limited and the Ohio court may still resolve related issues under the State Constitution. The ruling was sent back to the lower courts for further proceedings.

Dissents or concurrances

Justice Ginsburg (joined by Justice Breyer) agreed with the short opinion’s rational-basis approach. Justice Stevens dissented, arguing the dispute mainly concerns state universities and academic freedom and warning the case had little national significance.