United Mine Workers v. United Mine Workers

United Mine Workers v. United Mine Workers

Opinion

 [*909]  WILKEY, C.J.:

Appellant is a local labor organization composed of clerks, medical assistants and hospital clerks. The members of the Local are employed in various clerical and administrative capacities by the United Mine Workers of America Welfare and Retirement Fund. ¹ In turn the Fund is partially controlled by and receives a substantial portion of its assets from members of the United Mine Workers of America, an international labor union and appellee herein. The net result was that members of the Local were indirectly but essentially employed by the organization (International) which was supposed to represent them against their employer, (Fund) an interrelationship which continued for twenty years.

 [**2]  I. Actions of the Trial Examiner and District Court 

Twenty years was sufficient to bring this situation to the attention of the ever-watchful National Labor Relations Board. After hearing a Trial Examiner found that the employer (Fund) was engaged in unfair labor practices with respect to the Local. ² A major basis for this finding was the participation of supervisory personnel of the Fund in the affairs of the Local. The Trial Examiner also found that the Local was disqualified to represent the Fund's employees by reason of the Local's affiliation with the International. Since the Fund's payroll goes to the employees which the International represents, and the International helps to name the Fund's trustees, the Trial Examiner found an unacceptable conflict of interest to exist.

After posting the required notice, the Local met to consider the effect of the Examiner's decision. The remedial [**3]  action decided upon was to take a secret ballot on a resolution providing for both disaffiliation from the International and separation of the Local's Death Benefit Fund. Based on the Examiner's opinion, fifty-eight alleged supervisory personnel were notified of their purported  [*910]  ineligibility for membership and were thus not allowed to vote on the resolution.

Alleging that the disqualification of the supervisors and various other acts constituted a breakdown in democratic procedures, the International placed the Local under a trusteeship. This trusteeship froze the Local's bank account, impounded the ballots on the disaffiliation resolution, and took over management of the Local's affairs. The Local responded by bringing suit against the International seeking a temporary restraining order, followed by a preliminary and permanent injunction, and damages. ³ The District Court granted the temporary restraining order and permitted the ballots to be counted, revealing that the resolution to disaffiliate had passed by the decisive margin of 203 to 33. After trial on the merits, the District Court found for the International, holding the disaffiliation vote to be invalid [**4]  and denying preliminary and permanent injunctions and the request for damages. ⁴ The Local now seeks reversal of this action of the trial court.

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