Minnesota Bd. for Community Colleges v. Knight, Court Case

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Excerpt:

The Minnesota Public Employment Labor Relations Act (PELRA) authorizes state employees to bargain collectively over terms and conditions of employment. The statute also grants professional employees, such as college faculty, the right to “meet and confer” with their employers on matters related to employment that are outside the scope of mandatory bargaining. However, if professional employees forming an appropriate bargaining unit have selected an exclusive representative for mandatory bargaining, their employer may “meet and confer” on nonmandatory subjects only with that representative. Appellant Minnesota State Board for Community Colleges (Board) operates the Minnesota community college system, and appellant Minnesota Community College Faculty Association (MCCFA) is the designated exclusive representative of the faculty of the State’s community colleges. On the state level, MCCFA and the Board established “meet and confer” committees to discuss policy questions applicable to the entire system. On the campus level, the MCCFA chapters and the college administrations created local “meet and confer” committees to discuss policy questions applicable only to the campus. Appellees, 20 Minnesota community college faculty instructors who are not members of MCCFA, filed suit in Federal District Court, challenging, inter alia, the constitutionality of MCCFA’s exclusive representation of community college faculty in the “meet and confer” processes. The District Court held that the “meet and confer” provisions of PELRA deprived appellees of their First and Fourteenth Amendment speech and associational rights by denying them an opportunity to participate in their employer’s making of policy, and the court granted declaratory and injunctive relief.

The Minnesota Public Employment Labor Relations Act (PELRA) authorizes state employees to bargain collectively over terms and conditions of employment. The statute also grants professional employees, such as college faculty, the right to “meet and confer” with their employers on matters related to employment that are outside the scope of mandatory bargaining. However, if professional employees forming an appropriate bargaining unit have selected an exclusive representative for mandatory bargaining, their employer may “meet and confer” on nonmandatory subjects only with that representative. Appellant Minnesota State Board for Community Colleges (Board) operates the Minnesota community college system, and appellant Minnesota Community College Faculty Association (MCCFA) is the designated exclusive representative of the faculty of the State’s community colleges. On the state level, MCCFA and the Board established “meet and confer” committees to discuss policy questions applicable to the entire system. On the campus level, the MCCFA chapters and the college administrations created local “meet and confer” committees to discuss policy questions applicable only to the campus. Appellees, 20 Minnesota community college faculty instructors who are not members of MCCFA, filed suit in Federal District Court, challenging, inter alia, the constitutionality of MCCFA’s exclusive representation of community college faculty in the “meet and confer” processes. The District Court held that the “meet and confer” provisions of PELRA deprived appellees of their First and Fourteenth Amendment speech and associational rights by denying them an opportunity to participate in their employer’s making of policy, and the court granted declaratory and injunctive relief.

Held:

The “meet and confer” provisions do not violate appellees’ constitutional rights. Pp. 280-292.

(a) Appellees have no constitutional right, either as members of the public, as state employees, or as college instructors, to force officers of the State acting in an official policymaking capacity to listen to appellees’ [465 U.S. 271, 272] views. Nothing in the First Amendment or in this Court’s case law interpreting it suggests that the rights to speak, associate, and petition require government policymakers to listen or respond to communications of members of the public on public issues. Neither appellees’ status as public employees nor the fact that an academic setting is involved gives them any special constitutional right to a voice in the making of policy by their employer. Even assuming that First Amendment speech rights take on a special meaning in an academic setting, they do not require government to allow teachers to participate in institutional policymaking. Pp. 280-288.

(b) Appellees’ speech and associational rights have not been infringed by PELRA’s restriction of participation in “meet and confer” sessions to the faculty’s exclusive representative. The State has not restrained appellees’ freedom to speak on any education-related issue or to associate or not to associate with whom they please, including the exclusive representative. Nor has the State attempted to suppress ideas. Similarly, appellees’ associational freedom has not been impaired, since they are free to form whatever advocacy groups they like. Pp. 288-290.

(c) Appellees’ exclusion from “meet and confer” sessions does not deny them equal protection of the laws in violation of the Fourteenth Amendment. The State has a legitimate interest in ensuring that its public employers hear one, and only one, voice presenting the majority view of its professional employees on employment-related policy questions, and permitting selection of “meet and confer” representatives to be made by the exclusive representative is a rational means of serving that interest. Pp. 291-292.
571 F. Supp. 1, reversed.

O’CONNOR, J., delivered the opinion of the Court, in which BURGER, C. J., and WHITE, BLACKMUN, and REHNQUIST, JJ., joined. MARSHALL, J., filed an opinion concurring in the judgment, post, p. 292. BRENNAN, J., filed a dissenting opinion, post, p. 295. STEVENS, J., filed a dissenting opinion, in all but Part III of which BRENNAN, J., joined, and in all but Part II of which POWELL, J., joined, post, p. 300.

Eric R. Miller argued the cause for appellants. With him on the briefs for appellants in No. 82-977 was Donald W. Selzer, Jr. Hubert H. Humphrey III, Attorney General of Minnesota, and Donald J. Mueting, Sheila S. Fishman, and Brad P. Engdahl, Special Assistant Attorneys General, filed briefs for appellant in No. 82-898. [465 U.S. 271, 273]

Edwin Vieira, Jr., argued the cause for appellees. With him on the brief was Darel F. Swenson.Fn

Fn [465 U.S. 271, 273] J. Albert Woll, Marsha S. Berzon, and Laurence Gold filed a brief for the American Federation of Labor and Congress of Industrial Organizations as amicus curiae urging reversal. Ann H. Franke, Lawrence White, and Ralph S. Spritzer filed a brief for the American Association of University Professors as amicus curiae.

JUSTICE O’CONNOR delivered the opinion of the Court.

The State of Minnesota authorizes its public employees to bargain collectively over terms and conditions of employment. It also requires public employers to engage in official exchanges of views with their professional employees on policy questions relating to employment but outside the scope of mandatory bargaining. If professional employees forming an appropriate bargaining unit have selected an exclusive representative for mandatory bargaining, their employer may exchange views on nonmandatory subjects only with the exclusive representative. The question presented in these cases is whether this restriction on participation in the nonmandatory-subject exchange process violates the constitutional rights of professional employees within the bargaining unit who are not members of the exclusive representative and who may disagree with its views. We hold that it does not.

Source:

Minnesota Board for Community Colleges v. Knight. 1984. 465 U.S. 271 (D. Minn. 4th Div. 1984). https://www.loc.gov/item/usrep465271/

Cite this page:

Supreme Court of the United States. 1983. "Minnesota Bd. for Community Colleges v. Knight, Court Case." History of Higher Education. https://higheredhistory.gmu.edu/primary-sources/minnesota-bd-for-community-colleges-v-knight-court-case/