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The exclusive agent's statutory authority to represent all members of a designated unit includes a statutory obligation to serve the interests of all members without hostility or discrimination toward any, to exercise its discretion with complete good faith and honesty, and to avoid arbitrary conduct. Thus, a complaint that alleges a breach by a labor union of this duty is grounded in federal statutes, and federal law therefore governs such cause of action.
On February 13, 1962, Benjamin Owens filed this class action against petitioners, as officers and representatives of the National Brotherhood of Packinghouse Workers and of its Kansas City Local No. 12 (the Union), in the Circuit Court of Jackson County, Missouri. Owens, a Union member, alleged that he had been discharged from his employment at Swift & Company's (Swift) Kansas City Meat Packing Plant in violation of the collective bargaining agreement then in force between Swift and the Union, and that the Union had "arbitrarily, capriciously and without just or reasonable reason or cause" refused to take his grievance with Swift to arbitration under the fifth step of the bargaining agreement's grievance procedures. Owens, whose duties required strenuous activity, was discharged on the ground of poor health. During the fourth grievance step, the union sent Owens to a physician for a complete examination. The report was unfavorable to Owens and the union decided not to take the grievance to arbitration. After a jury verdict for Owens, the trial judge set aside the verdict on the ground that the NLRB had exclusive jurisdiction over the controversy. The Kansas City Court of Appeals affirmed, but the Missouri Supreme Court reversed and ordered the jury's verdict reinstated.
Did the trial court err in setting aside the jury verdict on the ground that the NLRB had exclusive jurisdiction over the action?
The Supreme Court concluded that the state court had jurisdiction in this case and that federal law governed. However, because the Court held that the lower court did not apply the proper standard, the judgment below was reversed. According to the Court, Owens could not prevail because he failed to prove arbitrary or bad-faith conduct on the part of the union in processing his grievance.