Thompson v. Marietta Education Association, No. 19-4217 (6th Cir. 2020)
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The Marietta Education Association serves as the exclusive bargaining representative for the school district’s employees. After the Supreme Court’s decision in Janus v. AFSCME (2018), Thompson sued the Association and the Marietta Board of Education, arguing that Ohio’s scheme of exclusive public-sector union representation violates the First Amendment. Under Ohio law, a union may become the exclusive bargaining representative for all public employees in a bargaining unit upon proof that a majority of the bargaining unit’s members wish to be represented by the union, Ohio Rev. Code 4117.05(A)(1). Public employers are then prohibited from bargaining with individual employees and other labor organizations. Ohio law sets a broad scope for collective-bargaining negotiations. Thompson is not a member of the Association. She objects to its policies but because the union has been designated as her bargaining unit’s “exclusive representative,” the union has a statutory right to represent her. Thompson argued that Ohio’s system of exclusive public-sector bargaining violates her First Amendment rights.
The district court granted the defendants summary judgment. The Sixth Circuit affirmed. Ohio’s take-it-or-leave-it system is in direct conflict with the principles enunciated by the Supreme Court in Janus v. AFSCME (2018). In deciding Janus, however, the Court did not overrule Minnesota State Board for Community Colleges v. Knight (1984). Which directly controls the outcome of this case.
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