| Chauffeurs, Teamsters, and Helpers Local No. 391 v. Terry | ||||||||||||
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| Argued December 6, 1989 Decided March 20, 1990 |
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| Holding | ||||||||||||
| An action by an employee for a breach of a labor union's duty of fair representation entitles him to a jury trial under the Seventh Amendment. | ||||||||||||
| Court membership | ||||||||||||
| Chief Justice: William Rehnquist Associate Justices: William J. Brennan, Jr., Byron White, Thurgood Marshall, Harry Blackmun, John Paul Stevens, Sandra Day O'Connor, Antonin Scalia, Anthony Kennedy |
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| Case opinions | ||||||||||||
| Majority by: Marshall (parts I, II, III-B, IV) Joined by: Rehnquist, Brennan, White, Blackmun, Stevens Concurrence by: Marshall (part III-A) Joined by: Rehnquist, White, Blackmun Concurrence by: Brennan Concurrence by: Stevens Dissent by: Kennedy Joined by: O'Connor, Scalia |
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| Laws applied | ||||||||||||
| U.S. Const. amend. VII; | ||||||||||||
Chauffeurs, Teamsters, and Helpers Local No. William Hubbs Rehnquist (October 1 1924 – September 3 2005 was an American lawyer, jurist, and a political figure who served as an Associate Justice William Joseph Brennan Jr ( April 25, 1906 &ndash July 24, 1997) was an Associate Justice of the Supreme Court of the Byron Raymond White ( June 8, 1917 &ndash April 15, 2002) won fame both as a football Running back and as an associate justice of Thurgood Marshall ( July 2, 1908 – January 24, 1993) was an American Jurist and the first African American Harry Andrew Blackmun ( November 12, 1908 &ndash March 4, 1999) was an Associate Justice of the Supreme Court of the United States John Paul Stevens (born April 20, 1920) is currently the most senior Associate Justice of the Supreme Court of the United States. Sandra Day O'Connor (born March 26, 1930) is an American Jurist. (born March 11, 1936) is an American Jurist and the second most senior Associate Justice of the Supreme Court of the United States Anthony McLeod Kennedy (born July 23, 1936) has been an Associate Justice of the U Title 29 of the United States Code is a code that outlines labor in the United States 391 v. Terry, 494 U.S. 558 (1990), was a case in which the United States Supreme Court held that an action by an employee for a breach of a labor union's duty of fair representation entitled him to a jury trial under the Seventh Amendment. Case citation is the system used in many countries to identify the decisions in past Court cases either in special series of books called reporters Year 1990 ( MCMXC) was a Common year starting on Monday (link displays the 1990 Gregorian calendar) The Supreme Court of the United States is the highest judicial body in the United States and leads the federal judiciary. A trade union or labour union is an organization of workers who have banded together to achieve common goals in key areas such as wages hours and working conditions forming
Contents |
Facts
McLean Trucking Corporation and the defendant/petitioner union, Chauffeurs, Teamsters, and Helpers Local No. 391, were parties to a collective bargaining agreement which governed employment at McLean. A defendant or defender ( Δ in Legal shorthand) is any party who is required to answer the Complaint of a Plaintiff TemplateInfobox Union for usage-->The International Brotherhood of Teamsters ( IBT) formerly known by the Collective bargaining is the process whereby workers organize together to meet converse and compromise upon the work environment with their employers The plaintiffs/respondents in this matter were Union members employed as truck drivers by McLean. A plaintiff ( Π in Legal shorthand) also known as a claimant or complainant, is the party who initiates a Lawsuit In 1982, McLean began to shut down some of its terminals and reorganizing others. Year 1982 ( MCMLXXXII) was a Common year starting on Friday (link displays the 1982 Gregorian calendar) The company transferred plaintiffs to its terminal in Winston-Salem, North Carolina, and granted them special seniority rights over inactive employees at that terminal who had been temporarily laid off. Winston-Salem is a city in the US state of North Carolina. As of the 2000 census the city population was 185776 in 2004 the city annexed an additional 17483 Seniority is the concept of a person or group of people being in charge or in command of another person or group Layoff is the temporary suspension or permanent Termination of employment of an Employee or (more commonly a group of employees for Business reasons
After working at Winston-Salem for six weeks, the plaintiffs were alternately laid off and recalled several times. Some of the laid off truckers were stripped of their special seniority rights. The plaintiffs filed a grievance with the union, alleging that McLean had breached the collective bargaining agreement by giving inactive employees preference over them. The grievance committee ordered McLean to recall the plaintiffs and lay off the inactive drivers who had been recalled, and to recognize plaintiffs’ special seniority rights until the inactive employees were recalled properly. McLean obeyed the order of the grievance committee at first, but then recalled the inactive employees, causing them to gain seniority status over the plaintiffs. In the next round of layoffs, this meant that the plaintiffs were laid off first. Plaintiffs then filed another grievance with the union, alleging that McLean’s actions were intended to circumvent the grievance committee’s initial order. But the grievance committee held that McLean had acted legitimately. This pattern of temporary layoffs and recalls continued, prompting plaintiffs to file another grievance, but the Union did not refer the third grievance to a grievance committee, instead ruling that the relevant issues had already been decided.
In July 1983, plaintiffs brought suit against both the Union and McLean in the United States District Court for the Middle District of North Carolina, alleging that McLean had violated the collective bargaining agreement in violation of the Labor Management Relations Act, , and alleging that the Union had breached its duty of fair representation. Year 1983 ( MCMLXXXIII) was a Common year starting on Saturday (link displays the 1983 Gregorian calendar) The US District Court for the Middle District of North Carolina 24 counties in the center of North Carolina. Title 29 of the United States Code is a code that outlines labor in the United States Plaintiffs requested a permanent injunction requiring the defendants to restore their seniority and cease their illegal activity. An injunction is an Equitable remedy in the form of a Court order, whereby a party is required to do or interact with in certain ways all right or to refrain from They further requested compensatory damages for lost wages and health benefits. In Law, damages refers to the money paid or awarded to a Claimant (England Pursuer (Scotland or Plaintiff (US following a successful A wage is a compensation workers receive in exchange for their labor. The term health insurance is generally used to describe a form of Insurance that pays for medical expenses McLean filed for bankruptcy in 1986, and all the claims against it were voluntarily dismissed. The United States Constitution (Article 1 Section 8 Clause 4 authorizes Congress to enact "uniform Laws on the subject of Bankruptcies throughout Year 1986 ( MCMLXXXVI) was a Common year starting on Wednesday (link displays 1986 Gregorian calendar) Voluntary dismissal is when a law suit is terminated by request of the Plaintiff (the party originally bringing the suit to court
Plaintiffs had requested a jury trial in their pleadings, but the Union moved to strike the demand for a jury trial, on the grounds that the no right to a jury trial exists in a duty of fair representation suit. In Law as practiced in countries that follow the English model a pleading is a formal written statement filed with a Court by parties in a Civil action The District Court denied the defendant’s motion to strike, and the United States Court of Appeals for the Fourth Circuit affirmed, holding that the Seventh Amendment entitled the plaintiffs to a jury trial on their claims for monetary damages. The United States Court of Appeals for the Fourth Circuit is a federal court located in Richmond Virginia with Appellate jurisdiction over the
Majority opinion
Justice Marshall wrote for the majority. Thurgood Marshall ( July 2, 1908 – January 24, 1993) was an American Jurist and the first African American He began his opinion by explaining that the right to a jury trial provided by the Seventh Amendment encompasses more than the common law forms of action recognized in 1791 (when the Bill of Rights was ratified), but rather any lawsuit in which parties’ legal rights were to be determined, as opposed to suits which only involve equitable rights and remedies. Common law refers to law and the corresponding legal system developed through decisions of courts and similar tribunals rather than through legislative statutes or executive The Forms of Action were the different procedures by which a legal claim could be made in the early history of the English common law. Year 1791 ( MDCCXCI) was a Common year starting on Saturday (link will display the full calendar of the Gregorian calendar (or a Common A Bill of Rights is a list or summary of rights that are considered important and essential by a group of people In law a lawsuit is a civil action brought before a Court in which the party commencing the action the Plaintiff, seeks a legal or equitable remedy Equity is the name given to the set of legal principles in jurisdictions following the English common law tradition which supplement strict rules of law where In law equitable remedies are the remedies developed and granted by the old courts of equity, such as the Court of Chancery in England and still available today He proposed a two-part test, first comparing the statutory action created by Congress to the 18th century actions brought in the courts of England prior to the merger of the courts of law and equity; then, examining the remedy sought by the plaintiff to determine whether it was legal or equitable in nature. A statute is a formal written enactment of a Legislative authority that governs a Country, State, City, or County. The United States Congress is the bicameral Legislature of the federal government of the United States of America, consisting of two houses The 18th century lasted from 1701 to 1800 in the Gregorian calendar, in accordance with the Anno Domini / Common Era numbering system England is a Country which is part of the United Kingdom. Its inhabitants account for more than 83% of the total UK population whilst its mainland
Since actions to enforce collective bargaining agreements were unknown in 18th-century England (such agreements were unlawful at the time), the union argued that the action brought by the plaintiffs was, in essence, an attempt to vacate an arbitration award, which historically was considered an action in equity. Arbitration, a form of Alternative dispute resolution (ADR is a legal technique for the resolution of Disputes outside the Courts wherein the Marshall rejected this argument because there had been no arbitration with regards to the union’s duty of fair representation. The union further argued that the suit was comparable to an action for breach of fiduciary duty (e. fiduciary duty is a legal relationship of confidence or trust between two or more parties most commonly a fiduciary or Trustee and a principal g. a suit concerning a trust), which was also considered an equitable action. In Common law legal systems a trust is an arrangement whereby Property (including real tangible and intangible is managed by one person (or persons or organizations The plaintiffs countered by comparing their suit to an action against an attorney for malpractice, which was an action at law. An attorney at law (or attorney-at-law) in the United States is a practitioner in a court of law who is legally qualified to prosecute In Law, malpractice is a type of negligence in which the Misfeasance, Malfeasance or Nonfeasance of a Professional, under a duty
Marshall conceded that the analogy to a trust action was more convincing, but reasoned that the right to a jury trial depended more on the nature of the issues to be tried. Although there was a fiduciary duty issue between the plaintiffs and the union, there was also an underlying breach of contract—that of the collective bargaining agreement between McLean and the plaintiffs. Breach of contract is a Legal concept in which a Binding agreement or bargained-for exchange is not honored by one or more of the parties to the contract by non-performance
Since the first part of the analysis failed to produce a dispositive result, Marshall then turned to the type of relief the plaintiffs sought. The only remaining remedy the plaintiffs sought against the union was compensatory damages, which are the traditional legal remedy. While restitutionary remedies such as back pay and benefits may be characterized as equitable when sought from an employer, the damages here were sought from the Union. The law of restitution is the law of gains-based recovery It is to be contrasted with the law of compensation, which is the law of loss-based recovery Thus, Marshall held that the plaintiffs were requesting a legal remedy, and therefore, on the balance of the issues, were entitled to have their case heard by a jury.
Brennan’s concurrence
Justice Brennan concurred, but desired to simplify the test for determining a plaintiff’s Seventh Amendment rights. William Joseph Brennan Jr ( April 25, 1906 &ndash July 24, 1997) was an Associate Justice of the Supreme Court of the Specifically, he felt that it was unnecessary to examine the nature of the action itself, but rather to simply examine the type of relief requested by the plaintiff. If the plaintiff requested a legal remedy (such as monetary damages), Brennan would simply assume that the right to a jury trial existed, unless Congress had assigned the particular action to a non-Article III tribunal, and a jury trial would frustrate the intent of Congress. A legal remedy (also judicial relief) is the means a Court of law, usually in the exercise of civil law jurisdiction enforces a Right, imposes In the United States, a federal tribunal may be either a court or another adjudicative body and can be classified as either an Article I tribunal or an Article III tribunal
Brennan went on to criticize the Court’s historical analysis of traditional equitable and legal causes of action. In the law a cause of action (sometimes called a claim) is a set of facts sufficient to justify a right to sue Many of the statutory rights created by Congress are not analogous to anything which existed in the courts of 18th-century England, and judges lack the historical training to analyze such matters consistently. Different justices and historians have come to different conclusions as to what is analogous to a “legal” or “equitable” action. He concluded that the right to a jury trial was too important for the Court to allow for such an uncertainty.
Stevens’ concurrence
Justice Stevens concurred separately, on similar grounds as Justice Brennan did. John Paul Stevens (born April 20, 1920) is currently the most senior Associate Justice of the Supreme Court of the United States. He felt that the Court’s attempt to find an 18th-century common law analogue to the collective-bargaining and fair representation actions in this case was a misguided historical judgment, and that the type of relief sought by the plaintiff was the relevant inquiry. He explained that it was perfectly rational to have members of the community—i. e. a jury of one’s peers—hear such a case.
Dissent
Justice Kennedy dissented, arguing that the majority’s analogy to an equitable trust action should have been dispositive in this case. Anthony McLeod Kennedy (born July 23, 1936) has been an Associate Justice of the U He further argued that the relationship between the union and its workers was more similar to the relationship between a trustee and a beneficiary than an attorney and his client, because a union had a duty of fair representation to all of its workers and did not normally be compelled to act as an agent by one beneficiary. He also stated that the relief sought by the plaintiffs was equitable in nature, because it sought to make the plaintiffs whole, and that the majority unnecessarily separated out the legal and equitable issues in this case.
Justice Kennedy defended the historical comparison of the cause of action to the “suits at common law” available in 1791. He felt that to expand the right beyond what was available to plaintiffs at the time of the ratification of the Bill of Rights was nothing more than rewriting the Constitution, stating “[w]e cannot preserve a right existing in 1791 unless we look to history to identify it”. 494 U. S. at 593.
See also
External links
- ^ 494 U.S. 558 Full text of the opinion courtesy of Findlaw. This is a list of all the United States Supreme Court cases from volume 494 of the United States Reports: Preseault v com.
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