Uradnik v. Inter Faculty Organization, No. 19-3749 (8th Cir. 2021)
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Plaintiff, a tenured professor, filed suit against the University, a faculty union, and the Board of Trustees, alleging First and Fourteenth Amendment violations. Plaintiff claimed that the designation of IFO as plaintiff's exclusive representative violates the First Amendment by wrongly compelling her to speak through and associate with an entity with which she disagrees. Plaintiff also claimed that granting preferences to IFO members to serve on meet-and-confer committees discriminates against her and others who declined to associate with the union.
The Eighth Circuit affirmed the district court's grant of summary judgment to defendants on all of plaintiff's claims. Because plaintiff properly concedes that the district court correctly rejected her compelled-speech claim (Count I) under Minnesota State Board of Community Colleges v. Knight, 465 U.S. 271 (1984), the court affirmed the district court's grant of summary judgment on her Count 1 claims. Furthermore, the district court correctly rejected plaintiff's invitation to read Count II as an unconstitutional-conditions claim for three reasons: first, the complaint's text does not support this reading; second, there are inconsistencies in plaintiff's filings; and plaintiff's claim that IFO's meet-and-confer rights under Minnesota law discriminate against her associational preferences is similar to Knight. Finally, the court concluded that the district court did not abuse its discretion in denying plaintiff's request for leave to amend her complaint, which she made in her Rule 59(e) motion to vacate the judgment.
Court Description: [Grasz, Author, with Gruender and Kelly, Circuit Judges] Civil case - Minnesota Public Employment Labor Relations Act. In this action, a college teacher alleged that designating the Inter Faculty Organization as her exclusive bargaining representative violates the First Amendment, and discriminates against those who decline to associate with the union. The district court did not err in granting defendants summary judgment on plaintiff's Fist Amendment claim under Minnesota State Board of Community Colleges v. Knight, 465 U.S. 271 (1984); nor did the court err in rejecting plaintiff's invitation to read her second count for compulsory association as an unconditional-conditions claim; no error in denying plaintiff's request for leave to amend her complaint, which was made in her Rule 59(e) motion to vacate the judgment.
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