## Facts

- Ohio enacted Ohio Rev. Code Ann. § 3345.45 after concerns that public university faculty were spending less time teaching and more time on research.
- The statute required workload standards for public university instructional duties and provided that those standards would not be subject to collective bargaining.
- Central State University adopted a faculty workload policy under the statute and notified the faculty union, AAUP, that it would not bargain over workload.
- AAUP sued in Ohio state court for declaratory and injunctive relief, alleging the statute violated equal protection by singling out professors as public employees barred from bargaining over workload.
- The Ohio Supreme Court held the statute unconstitutional, finding no rational relationship between the bargaining exemption and the State’s objective.
- The U.S. Supreme Court granted certiorari and reversed.

## Issues

1. Whether Ohio’s exclusion of public university faculty instructional-workload standards from collective bargaining violates the Fourteenth Amendment Equal Protection Clause.

## Decision

- Reversed and remanded (per curiam), 8–1.
- The Court held the statute did not violate equal protection because it was rationally related to a legitimate governmental objective.
- The Court concluded that removing workload standards from bargaining was a rational legislative step to increase faculty classroom teaching time.
- The Court rejected the Ohio Supreme Court’s demand for record evidence showing collective bargaining caused reduced teaching time.

## Legal Principles

- When a classification does not involve a fundamental right or a suspect class, it satisfies equal protection if there is a rational relationship between disparate treatment and a legitimate governmental purpose.
- Under rational-basis review, legislatures need not produce empirical proof that the regulatory mechanism caused the problem being addressed; a plausible connection to the stated objective is sufficient.
- Courts may not apply a heightened evidentiary requirement that effectively tightens rational-basis review beyond what equal protection precedent permits.

## Conclusion

Ohio’s decision to exempt public university instructional-workload standards from collective bargaining survived rational-basis review because it plausibly furthered the legitimate objective of increasing time spent by faculty in the classroom, and equal protection does not require evidentiary proof of causation in the legislative record.


Cent. State Univ. v. Am. Ass'n of Univ. Professors, 526 U.S. 124 (1999)