Central State Univ. v. American Assn. of Univ. Professors, Central State Univ. Chapter, 526 U.S. 124, 3 (1999) (per curiam)

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126

CENTRAL STATE UNIV. v. AMERICAN ASSN. OF UNIV. PROFESSORS, CENTRAL STATE UNIV. CHAPTER

Per Curiam

In 1994, petitioner Central State University adopted a workload policy pursuant to § 3345.45 and notified respondent, the certified collective-bargaining agent for Central State's professors, that it would not bargain over the issue of faculty workload. Respondent subsequently filed a complaint in Ohio state court for declaratory and injunctive relief, alleging that § 3345.45 created a class of public employees not entitled to bargain regarding their workload and that this classification violated the Equal Protection Clauses of the Ohio and United States Constitutions.

By a divided vote, the Ohio Supreme Court agreed with respondent that § 3345.45 deprived public university professors the equal protection of the laws. See 83 Ohio St. 3d 229, 699 N. E. 2d 463 (1998). The court acknowledged that Ohio's purpose in enacting the statute was legitimate and that all legislative enactments enjoy a strong presumption of constitutionality. Id., at 234-235, 699 N. E. 2d, at 468- 469. Nonetheless, the court held that § 3345's collective-bargaining exemption bore no rational relationship to the State's interest in correcting the imbalance between research and teaching at its public universities. See id., at 236-239, 699 N. E. 2d, at 469-470. The State had argued that achieving uniformity, consistency, and equity in faculty workload was necessary to recapture the decline in teaching, and that collective bargaining produced variation in workloads across universities in departments having the same academic mission. Id., at 236, 699 N. E. 2d, at 469. Reviewing evidence that the State had submitted in support of this

shall work with state universities "to ensure that no later than [the] fall term 1994, a minimum ten percent increase in statewide undergraduate teaching activity be achieved to restore the reductions experienced over the past decade. Notwithstanding section 3345.45 of the Revised Code, any collective bargaining agreement in effect on the effective date of this act shall continue in effect until its expiration date." Amended Substitute House Bill No. 152, § 84.14, 145 Ohio Laws 4539 (effective July 1, 1993).

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