Minnesota State Board for Community College vs. Knight
465 U.S. 271 (1984)
by
Laura Graff

Facts of the Case

In the state of Minnesota, the Minnesota Public Employment Labor Relations Act authorized state employees to bargain collectively over the terms and conditions of their employment or occupation with their employer.  This also allowed professional employees liberty to “meet and confer” with their employers on issues related to their employment, even if they were not within the range of mandatory bargaining.  Professional employees, such as college faculty could form a bargaining “unit”: a group of teachers seeking a negotiation with their employer, and then select one representative for bargaining.  Thus, a bargaining unit provided that the employer “meet and confer” on the matters only with that selected representative.

In 1984, the twenty community college faculty teachers in the Minnesota school district filed a law suit in the federal district court.  The twenty faculty members challenged the constitutionality of the Minnesota Community College Faculty Association’s selective and exclusive representation of faculty in the “meet and confer” procedure.  This challenge was based on the fact that not all members of the bargaining unit had the ability to speak during the meetings.  This questioned their rights under the First and Fourteenth Amendments of the United States Constitution which provide that “Congress shall make no law…abridging the freedom of speech or of the press…” 

Court Decision

The Supreme Court ruled, in 1984, with a six to three decision that the “meet and confer” provisions did not deprive faculty of their rights under the First and Fourteenth Amendment, because it did not deny them equal representation.

Reasons for Decision
           
The Supreme Court’s ruling was based on the fact that the First and Fourteenth Amendments do not require the government to permit teachers to participate in the policymaking of their employment.  Also, the faculty’s speech was not by any means denied under the “meet and confer” procedure.  The faculties were never deprived of the right to speak about the issues, nor were they under represented.  The State Board for Community Colleges did not restrict the faculty from forming advocacy groups, and therefore did not impair their freedoms.  Lastly, the exclusive representation involved in the “meet and confer” meetings did not deny any faculty member equal protection under the Fourteenth Amendment of the Constitution.  The idea behind a single representative presenting the opinions of the bargaining unit was solely to aid the public employers in clearly understanding the majority view of their employees in an organized manner.