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Uradnik v. Inter Faculty Org.

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Uradnik v. Inter Faculty Org.
Case number: 19-3749
Status: Terminated
Important dates
Filed: July 6, 2018
District court decision:
Dec. 5, 2019
Appeals court decision:
June 16, 2021
District court outcome
The court ruled in favor of the defendants, upholding the Minnesota state law the plaintiff was challenging.
Appeals court outcome
The appellate court affirmed the district court’s decision.

This case is one of over a hundred public-sector union lawsuits Ballotpedia tracked following the U.S. Supreme Court's 2018 decision in Janus v. AFSCME. These pages were updated through February 2023 and may not reflect subsequent case developments. For more information about Ballotpedia's coverage of public-sector union policy in the United States, click here. Contact our team to suggest an update.

Uradnik v. Inter Faculty Org. was decided on June 16, 2021, by the U.S. Court of Appeals for the Eighth Circuit. The plaintiff challenged the constitutionality of Minnesota law allowing unions to become exclusive bargaining agents for public-sector employees. The U.S. District Court for the District of Minnesota ruled in favor of the defendants on December 5, 2019, and the Eighth Circuit affirmed.[1][2]

HIGHLIGHTS
  • The parties to the suit: The plaintiff was political science professor Kathleen Uradnik. The defendants were the Inter Faculty Organization, St. Cloud State University, and the Minnesota State Colleges and Universities Board of Trustees.
  • The issue: Whether it violates the First Amendment to appoint a labor union to represent and speak for public-sector employees who have opted out of joining the union.
  • The presiding judges: Judge Paul Magnuson presided over the case in the district court. A three-judge appellate panel included Judges Steven Grasz, Raymond Gruender, and Jane Kelly.
  • The outcome: The Eighth Circuit affirmed the district court’s decision in favor of the defendants.

    • Procedural history

    The plaintiff was Kathleen Uradnik, a political science professor at St. Cloud State University. Attorneys from The Buckeye Institute and Baker & Hostetler represented her.

    The defendants were the Inter Faculty Organization (IFO), St. Cloud State University, and the Minnesota State Colleges and Universities Board of Trustees. Attorneys from Cummins & Cummins and the state attorney general’s office represented the defendants.

    Uradnik’s original complaint, filed on July 6, 2018, in the U.S. District Court for the District of Minnesota, claimed that by “designating the Union as the Plaintiff’s exclusive representative, Minnesota law and the [IFO’s collective bargaining agreement] violate the Plaintiff’s rights under the First and Fourteenth Amendments to the United States Constitution.” Uradnik also claimed the union violated the First Amendment because it “[negotiated] special preferences for union members, including preferences that tilt the scales in union members’ favor in such matters as tenure and promotion decisions.”[3]

    Minnesota’s Public Employment Labor Relations Act allows for “an employee organization which has been certified by the commissioner … to meet and negotiate with the employer on behalf of all employees in the appropriate unit.”[4]

    On September 27, 2018, the U.S. District Court for the District of Minnesota denied Uradnik’s motion for a preliminary injunction to block the union from being regarded as her representative. Uradnik appealed the decision to the U.S. Court of Appeals for the Eighth Circuit, which affirmed the lower court’s ruling on December 3, 2018, and then to the U.S. Supreme Court, which denied the appeal on April 29, 2019.

    The case then resumed in the District of Minnesota, and the court ruled in favor of the defendants on December 5, 2019. Uradnik then appealed the decision to the Eighth Circuit, which affirmed the district court's ruling on June 16, 2021.

    Below is a brief procedural history of the lawsuit:[1][5][2][6][7]

    • July 6, 2018: Plaintiff files a complaint challenging Minnesota state law allowing a labor union to represent and speak for public-sector employees who have declined to join the union.
    • July 31, 2018: Plaintiff files a motion for a preliminary injunction to block the union from being regarded as her representative.
    • September 27, 2018: U.S. District Court for the District of Minnesota denies plaintiff’s motion for preliminary injunction.
    • September 28, 2018: Plaintiff files an appeal in the U.S. Court of Appeals for the Eighth Circuit.
    • December 3, 2018: Eighth Circuit affirms district court’s decision denying plaintiff’s motion for preliminary injunction.
    • December 4, 2018: Plaintiff files a petition for a writ of certiorari with the U.S. Supreme Court.
    • April 29, 2019: Supreme Court denies plaintiff’s petition.
    • May 2, 2019: U.S. District Court for the District of Minnesota is notified of the Supreme Court's denial of plaintiff’s petition and proceedings resume in district court.
    • September 12, 2019: Defendants file a motion for a judgment on the pleadings or summary judgment.
    • December 5, 2019: Defendants' motion for summary judgment is granted.
    • December 10, 2019: Plaintiff files a motion for the court to vacate its order.
    • December 17, 2019: The court denies the plaintiff's motion to vacate.
    • December 23, 2019: Plaintiff files an appeal in the U.S. Court of Appeals for the Eighth Circuit.
    • February 18, 2020: Plaintiff files an opening brief in the Eighth Circuit.
    • June 16, 2021: Eighth Circuit affirms district court's decision in favor of the defendants.

    For a list of available case documents, click here.

    Decision

    District Court

    On December 5, 2019, Judge Paul Magnuson ruled in favor of the defendants, citing the Supreme Court’s decision in Minnesota State Board for Community Colleges v. Knight (1984). In that case, a group of non-union community college instructors objected to a Minnesota statute allowing an exclusive representative to speak on behalf of all of a bargaining unit’s employees at “meet and confer” sessions. The Supreme Court ruled Minnesota had “in no way restrained [the instructors’] freedom to speak … or their freedom to associate or not to associate with whom they please.”[8]

    Magnuson wrote in the court's opinion, “Knight and [Bierman v. Dayton] foreclose Plaintiff’s claims. No genuine dispute of material fact exists, and she cannot prevail on this issue. Defendants are entitled to judgment as a matter of law.”[9]

    Magnuson joined the court in 1981 after being nominated by President Ronald Reagan (R).

    Appeals court

    A three-judge panel of the U.S. Court of Appeals for the Eighth Circuit unanimously affirmed the district court’s decision on June 16, 2021. Judge Steven Grasz, who was appointed to the court by President Donald Trump (R), wrote:[10]

    “ We review the district court’s grant of summary judgment de novo, viewing the record in the light most favorable to, and drawing all reasonable inferences for, Uradnik. … We review the district court’s decision to deny leave to amend for abuse of discretion and any underlying legal determinations de novo. … Because Uradnik properly concedes that the district court correctly rejected her compelled-speech claim (Count I), we affirm the district court’s grant of summary judgment on her Count I claims. Like the district court, we are bound by precedent, and only the Supreme Court can provide the relief she seeks. …

    Otherwise, Uradnik mainly focuses her brief on challenging the district court’s holding that she did not properly plead an unconstitutional-conditions claim in Count II of her complaint. We affirm the district court.[11]

    		”

    Judges Raymond Gruender, appointed by President George W. Bush (R), and Jane Kelly, appointed by President Barack Obama (D), joined Grasz’s opinion.

    Legal context

    Janus v. AFSCME (2018)

    See also: Janus v. AFSCME

    On June 27, 2018, the Supreme Court of the United States issued a 5-4 decision in Janus v. American Federation of State, County, and Municipal Employees (Janus v. AFSCME), ruling that public-sector unions cannot compel non-member employees to pay fees to cover the costs of non-political union activities.[12]

    This decision overturned precedent established in Abood v. Detroit Board of Education in 1977. In Abood, the high court held that it was not a violation of employees' free-speech and associational rights to require them to pay fees to support union activities from which they benefited (e.g., collective bargaining, contract administration, etc.). These fees were commonly referred to as agency fees or fair-share fees.[12]

    Justice Samuel Alito authored the opinion for the court majority in Janus, joined by Chief Justice John Roberts and Justices Anthony Kennedy, Clarence Thomas, and Neil Gorsuch. Alito wrote, "Abood was poorly reasoned. It has led to practical problems and abuse. It is inconsistent with other First Amendment cases and has been undermined by more recent decisions. Developments since Abood was handed down have shed new light on the issue of agency fees, and no reliance interests on the part of public-sector unions are sufficient to justify the perpetuation of the free speech violations that Abood has countenanced for the past 41 years. Abood is therefore overruled."[12]

    Related litigation

    To view a complete list of the public-sector labor lawsuits Ballotpedia tracked between 2019 and 2023, click here.

    Number of federal lawsuits by circuit

    Between 2019 and 2023, Ballotpedia tracked 191 federal lawsuits related to public-sector labor laws. The chart below depicts the number of suits per federal judicial circuit (i.e., the jurisdictions in which the suits originated).

    Public-sector labor lawsuits on Ballotpedia

    See also: Public-sector union policy in the United States, 2018-2023

    Click show to view a list of cases with links to our in-depth coverage.

    v • e
    Public-sector labor lawsuits
    Federal lawsuits

    Adams v. Teamsters Union Local 429 • Akers v. Maryland State Education Association • Aliser v. SEIU California • Allen v. Ohio Civil Service Employees Association • Allen v. Santa Clara County Correctional • Anderson v. SEIU Local 503 • Babb v. California Teachers Association • Baisley v. International Association of Machinists and Aerospace Workers • Belgau v. Inslee • Bennett v. AFSCME • Bermudez v. SEIU Local 521 • Bierman v. Dayton • Boudreaux v. Louisiana State Bar • Boyle v. SEIU California • Brice v. California Faculty Association • California v. Azar • Campos v. Fresno Deputy Sheriff’s Association • Carey v. Inslee • Casanova v. IAM Local 701 • Chandavong et al. v. Fresno Deputy Sheriff's Association et al. • Cook v. Brown • Cooley v. California Statewide Law Enforcement Association • Crowe v. Oregon State Bar • Cruz v. Union Independiente Autentica de Empleados de la Autoridad de Acueductos y Alcantarillados • Danielson v. Inslee • Diamond v. Pennsylvania State Education Association • Doughty v. State Employees Association of New Hampshire, SEIU, Local 1984 • Durst v. OEA • Few v. United Teachers Los Angeles • File v. Hickey • Fischer v. Murphy • Fisk v. Inslee • Fizer v. Ohio Association of Public School Employees • Fleck v. Wetch • Grega v. Council of New Jersey State College Locals • Grossman v. Hawaii Government Employees Association • Gruber v. Oregon State Bar • Guppy v. City of Los Angeles • Halloran v. AFSCME Council 5 • Hamidi v. SEIU • Hannay v. Kent State • Hartnett v. Penn. State Education Association • Hendrickson v. AFSCME Council 18 • Hernandez v. AFSCME California • Hoekman v. Education Minnesota • Hough v. SEIU Local 521 • Imhoff v. California Teachers Association • Jackson v. Napolitano • James v. SEIU Local 688 • Janus v. AFSCME • Jarchow v. Wisconsin • Kabler v. United Food and Commercial Workers Union, Local 1776 Keystone State • Wenzig v. SEIU Local 668 • Kopie v. International Federation of Professional and Technical Employees • Kurk v. Los Rios Classified Employees Association • Lamberty et al. v. Connecticut State Police Union et al. • LaSpina v. SEIU Pennsylvania State Council • Lee v. Ohio Education Association • Leitch v. AFSCME • Littler v. Ohio Association of Public School Employees • Loescher v. Teamsters Local 320 • Lutter v. JNESO • Mandel v. SEIU Local 73 • Marsh v. AFSCME Local 3299 • Martin v. California Teachers Association • Masuo v. AFSCME AFL-CIO • Matthews v. United Teachers of Los Angeles • Mattos v. AFSCME Council 3 • Mayer v. Wallingford-Swathmore School District • McCain v. Ventura County Federation of College Teachers, AFT Local 1828 • McCollum v. NEA-Alaska • McCutcheon v. CWA Local 7076 • McDonald v. Firth • Mendez v. CTA • Miller v. Inslee • Misja v. PSEA • Molina v. SEIU Local 668 • Mooney v. Illinois Education Association • Nearman v. SEIU Local 503 • Neely v. AFSCME Council 13 • Nguyen v. Admin. and Residual Employees Union • Nichols v. Home Care Providers Union • O'Callaghan v. Drake • Ochoa v. Public Consulting Group • Ocol v. Chicago Teachers Union • Ogle v. Ohio Civil Service Employees Association, AFSCME, Local 11 • Oliver v. SEIU Local 668 • Pellegrino v. New York State United Teachers • Penning v. SEIU Local 1021 • Polk v. Yee • Popp v. ALPAI • Piekarski v. AFSCME Council 5 • Quirarte v. UDW AFSCME Local 3930 • Reisman v. Associated Faculties of the University of Maine • Rizzo-Rupon v. International Association of Machinists and Aerospace Workers, District Lodge 141 • Routh v. Inslee • Schaszberger v. AFSCME Council 13 • Schell v. Oklahoma Supreme Court Justices • Schumaker v. Inslee • Seager v. UTLA • Seidemann v. Professional Staff Congress • Smith v. AFSCME Council No. 8 • Smith v. New Jersey Education Association • Smith v. Bieker • Solomon v. AFSCME District Council 37 • Stroeder v. Service Employees International Union, Local 503 • Sweeney v. Raoul • Sweet v. California Association of Psychiatric Technicians • Taylor v. Heath • Thompson v. AFSCME Council 89, Local 4013 • Thompson v. Marietta Education Association • Thulen v. AFSCME • Uradnik v. Inter Faculty Org. • Utke v. University of Connecticut American Association of University Professors • Weyandt v. PSCOA • Wholean v. CSEA SEIU Local 2001 • Wilford v. National Education Association • Williams v. PSEA • Wolf v. University Professional & Technical Employees • Yates v. Hillsboro Unified School District • Yohn v. California Teachers Association

    See also

    External links

    Case documents

    Supreme Court

    Appeals court

    Trial court

    Footnotes

    1. ↑ 1.0 1.1 PacerMonitor, "Uradnik v. Inter Faculty Association et al," accessed June 25, 2021
    2. ↑ 2.0 2.1 PacerMonitor, "Kathleen Uradnik v. Inter Faculty Organization, et al," accessed June 25, 2021
    3. ↑ CourtListener, "Complaint," July 6, 2018
    4. ↑ Office of the Revisor of Statutes, "2020 Minnesota Statutes: Chapter 179A," accessed June 25, 2021
    5. ↑ PacerMonitor, "Kathleen Uradnik v. Inter Faculty Organization, et al," accessed June 25, 2021
    6. ↑ Supreme Court of the United States, "No. 18-719," accessed June 25, 2021
    7. ↑ The Buckeye Institute, "Timeline of Uradnik v. IFO," accessed June 25, 2021
    8. ↑ Justia, "Minn. Bd. Commun. for Colleges v. Knight, 465 U.S. 271 (1984)," accessed June 25, 2021
    9. ↑ PacerMonitor, "Memorandum and Order," December 5, 2019
    10. ↑ U.S. Court of Appeals for the Eighth Circuit, "No. 19-3749," June 16, 2021
    11. ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    12. ↑ 12.0 12.1 12.2 Supreme Court of the United States, Janus v. American Federation of State, County, and Municipal Employees, Council 31, et al., June 27, 2018
    v • e
    Public-sector union policy in the United States
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