Uradnik v. Inter Faculty Association

Background

Kathleen Uradnik, a tenured political science professor at St. Cloud State University, sued the Inter Faculty Association, St. Cloud State University, and the Board of Trustees of the Minnesota State Colleges and Universities. She alleged that the defendants violated her First and Fourteenth Amendment rights.

The Inter Faculty Association served as the exclusive representative for Uradnik and other faculty at Minnesota public universities under Minnesota’s Public Employment Labor Relations Act. That law allows employees in a bargaining unit to choose an exclusive representative to negotiate with the public employer about employment terms and conditions. It also allows public employees to meet and confer with the employer about matters outside mandatory negotiations, with the exclusive representative speaking for employees in those sessions. Uradnik was not a member of the Inter Faculty Association and disagreed with many of its positions.

Uradnik previously sought an injunction concerning her claim that the exclusive-representative system compelled her speech. The court denied that request, the Eighth Circuit affirmed that she had no chance of success on the claim, and the Supreme Court denied review.

Standard and Treatment of the Motions

The defendants moved for judgment on the pleadings or, alternatively, summary judgment. Because the court considered matters outside the pleadings, it treated the motions as motions for summary judgment. Summary judgment is appropriate when there is no genuine dispute about a material fact and the moving party is entitled to judgment under the law.

Compelled Speech Claim

Uradnik alleged that designating the Inter Faculty Association as the employees’ exclusive representative compelled her speech and violated the First and Fourteenth Amendments. She conceded that the current court was not the proper forum to obtain relief on this claim and stated that she was preserving it for appeal. The court also stated that, even if precedent had not already foreclosed the claim, the Public Employment Labor Relations Act survived the required constitutional review. Because there was no genuine dispute of material fact, the court held that the defendants were entitled to judgment as a matter of law on this claim.

Compelled Association Claim

Uradnik also alleged that the exclusive representation of her through the university’s “meet and confer” committees violated the First Amendment. She argued that the committees at St. Cloud State University differed from the processes the Supreme Court upheld in Minnesota State Board for Community Colleges v. Knight.

The court rejected that argument. It relied on Knight and an Eighth Circuit decision, Bierman v. Dayton, and stated that those decisions foreclosed Uradnik’s claims. The court had previously found that her compelled-association argument was virtually identical to arguments rejected in those cases.

Uradnik also argued in her opposition brief that not participating in the “meet and confer” committees prevented her from obtaining government opportunities and benefits. The court declined to consider the merits of that argument because her complaint did not allege the claimed deprivation. A party may not add a new claim or theory in a brief instead of filing an amended complaint.

Disposition

The court granted the defendants’ Motions for Summary Judgment, Docket Nos. 70 and 72, and ordered judgment to be entered. Judge Paul A. Magnuson concluded that no genuine dispute of material fact existed and that the defendants were entitled to judgment as a matter of law.