Thank You For Submiting Feedback!
Supreme Court of the United States
January 9, 1984, Argued ; June 12, 1984, Decided
[*528] [***462] [**2559] JUSTICE BRENNAN delivered the opinion of the Court.
The Labor-Management Reporting and Disclosure Act of 1959 (LMRDA or Act), 73 Stat. 522, as amended, 29 U. S. C. § 401 et seq., was Congress' first major attempt to regulate the internal affairs of labor unions. Title I of the Act provides a statutory "Bill of Rights" for union members, including various protections for members involved in union elections, with enforcement and appropriate remedies available in district court. Title IV, in contrast, provides an elaborate postelection procedure aimed solely at protecting union democracy through free and democratic elections, with primary responsibility for enforcement lodged with the Secretary of Labor. Resolution of the question presented by this case requires that we address the conflict that exists between the separate enforcement mechanisms included in these two Titles. In particular, we must determine whether suits alleging violations of Title I may properly be maintained in district court during the course of a union election.
The Court of Appeals approved a preliminary [****7] injunction issued by the District Court that enjoined an ongoing union [*529] election and ordered the staging of a new election pursuant to procedures promulgated by the court. After reviewing the complex statutory scheme created by Congress, we conclude that such judicial interference in an ongoing union election is not appropriate relief under § 102 of Title I, 29 U. S. C. § 412. We therefore reverse the Court of Appeals.
Local No. 82, Furniture and Piano Moving, Furniture Store Drivers, Helpers, [**2560] Warehousemen, and Packers (Local 82) represents approximately 700 employees engaged in the furniture moving business in the Boston, Mass., area. 2 The union is governed by a seven-member executive board whose officers, pursuant to § 401(b) of the LMRDA, 29 U. S. C. § 481(b), must be chosen by election no less than once every three years. These elections, consistent with the executive board's discretion under the union's bylaws and constitution, have traditionally been conducted by mail referendum balloting. The dispute giving rise to the present case stems from the union election that was regularly scheduled for the last two months of 1980.
[****8] On [***463] November 9, 1980, Local 82 held a meeting to nominate candidates for positions on its executive board. The meeting generated considerable interest, in part because dissident members of the union were attempting to turn the incumbent union officials out of office. Two aspects of the controversial meeting are especially important for present purposes. First, admission to the meeting was restricted to those members who could produce a computerized receipt showing that their dues had been paid up to date. Several union members, including respondent Jerome Crowley, were prohibited from entering the meeting because they did not have such dues receipts in their possession. Second, during the actual [*530] nominations process, there was disagreement relating to the office for which respondent John Lynch had been nominated. At the close of nominations, petitioner Bart Griffiths, the union's incumbent secretary-treasurer, declared himself the only candidate nominated for that office; at the same time, he included Lynch among the candidates selected to run for union president.
Full case includes Shepard's, Headnotes, Legal Analytics from Lex Machina, and more.
467 U.S. 526 *; 104 S. Ct. 2557 **; 81 L. Ed. 2d 457 ***; 1984 U.S. LEXIS 107 ****; 52 U.S.L.W. 4757; 101 Lab. Cas. (CCH) P11,034; 116 L.R.R.M. 2633
LOCAL NO. 82, FURNITURE & PIANO MOVERS, FURNITURE STORE DRIVERS, HELPERS, WAREHOUSEMEN & PACKERS, ET AL. v. CROWLEY ET AL.
Subsequent History: [****1] Petition For Rehearing Denied August 2, 1984.
Prior History: CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIRST CIRCUIT.
Disposition: 679 F.2d 978, reversed and remanded.
election, district court, union member, rights, remedies, ballots, violations, new election, nominations, supervise, legislative history, provisions, candidates, injunction, suits, policies, preliminary injunction, invalidate, purposes, courts, challenging, ongoing, statutory violation, appropriate relief, alleged violation, court supervision, federal court, postelection, leadership, aggrieved
Labor & Employment Law, Collective Bargaining & Labor Relations, Right to Organize, Enforcement of Bargaining Agreements, Constitutional Law, Bill of Rights, General Overview, Labor Arbitration, Discipline, Layoffs & Terminations, Civil Procedure, Justiciability, Exhaustion of Remedies, Governments, Local Governments, Elections, Legislation, Interpretation, Judicial Review, Remedies, Judgments, Relief From Judgments