Chauffeurs, Teamsters & Helpers, Local Union No. 171 v. International Brotherhood of Teamsters

871 F. Supp. 258, 1994 U.S. Dist. LEXIS 18862, 1994 WL 724893
CourtDistrict Court, W.D. Virginia
DecidedDecember 29, 1994
DocketCiv. A. No. 94-0983-R
StatusPublished

This text of 871 F. Supp. 258 (Chauffeurs, Teamsters & Helpers, Local Union No. 171 v. International Brotherhood of Teamsters) is published on Counsel Stack Legal Research, covering District Court, W.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Chauffeurs, Teamsters & Helpers, Local Union No. 171 v. International Brotherhood of Teamsters, 871 F. Supp. 258, 1994 U.S. Dist. LEXIS 18862, 1994 WL 724893 (W.D. Va. 1994).

Opinion

MEMORANDUM OPINION

TURK, District Judge.

This matter is before the court on plaintiffs’ motion for entry of a preliminary injunction and defendants’ motion to dismiss pursuant to Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). After careful consider[259]*259ation of the record, the applicable law, the briefs submitted by the parties, and the arguments presented by counsel at the hearing, the court finds that it must grant the motion to dismiss for lack of subject matter jurisdiction. Accordingly, the court must deny the motion for entry of a preliminary injunction.

I. BACKGROUND

In October, 1993, Chauffeurs, Teamsters and Helpers, Local Union No. 171 (“Local 171”), a local union of the International Brotherhood of Teamsters (“International”), held its most recent triennial officer election. Members of Local 171 voted by mail ballot. Local 171 sent out ballots to all members. Members then returned their ballots in two envelopes. The inner envelope held the actual ballot and remained sealed and unmarked. Local 171’s election procedure, however, required each member to write his name and address in the upper left hand corner of the outer envelope. Election procedure also mandated that any ballots not conforming to the name and address requirements be considered void. The purpose of this procedure was to ensure that Local 171 counted only the eligible votes.

Application of this procedure in the October, 1993 election resulted in the voiding of twenty-two percent of the secret ballots returned. After the election, the losing candidates filed an internal post-election protest pursuant to International’s constitution. On February 17, 1994, the Executive Board of Joint Council 83 denied the protest. The defeated candidates then appealed to the General Executive Board of International, which reversed the adverse decision of the Executive Board of the Joint Council and ordered Local 171 to conduct a rerun of the local officers’ election. The General Executive Board based its decision on confusing voting instructions and the large number of voided ballots.

Local 171, its officers, and two of its members brought the present suit under Title I of the Labor-Management Reporting and Disclosure Act (“LMRDA”), 29 U.S.C. §§ 411-13, and section 301 of the Labor Management Relations Act (“LMRA”), 29 U.S.C. § 185, against International and nineteen of its officials. Plaintiffs claim that defendants reversed the decision of the Joint Council for improper motives under Title I and in violation of International’s constitution. The essence of the relief plaintiffs seek is to validate the October, 1993 election and to enjoin International from requiring a rerun election. Plaintiffs have moved the court to enter a preliminary injunction; defendants have moved to dismiss for lack of subject matter jurisdiction. The court held a hearing on this matter on December 20, 1994; thus, the motions now are ripe for consideration.

II. ANALYSIS

The principle issue in this case is whether this action is, in effect, a suit under Title IV of the LMRDA, 29 U.S.C. §§ 481-83, regulating elections for union offices. As the court answers this question affirmatively, the exclusivity provision of Title IV1 bars the court from considering the merits of plaintiffs’ claims under Title I and section 301.

The United States Supreme Court has recognized and addressed the conflict between Title I and Title IV of the LMRDA. See Local No. 82, Furniture and Piano Moving v. Crowley, 467 U.S. 526, 104 S.Ct. 2557, 81 L.Ed.2d 457 (1984); Calhoon v. Harvey, 379 U.S. 134, 85 S.Ct. 292, 13 L.Ed.2d 190 (1964). Title I 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.” Crowley, 467 U.S. at 528, 104 S.Ct. 2557, 2559. Title IV, by contrast, “provides an elaborate postelection procedure aimed solely at protecting union democracy through free and democratic elections, with primary re[260]*260sponsibility for enforcement lodged with the Secretary of Labor.”2 Id.

The Court has reiterated the important policy behind the exclusivity provision of Title IV: “Congress’s intent ‘to allow unions great latitude in resolving their own internal controversies, and, where that fails, to utilize the agencies of Government most familiar with union problems to aid in bringing about a settlement through discussion before resort to the courts.’” Crowley, 467 U.S. at 548, 104 S.Ct. at 2569 (quoting Calhoon, 379 U.S. at 140, 85 S.Ct. at 296). In applying these policies, the Court has concluded that “the exclusivity provision ... plainly bars Title I relief when an individual union member challenges the validity of an election that has already been completed,” Crowley, 467 U.S. at 541, 104 S.Ct. at 2566, and that “Congress ... decided not to permit individuals to block or delay union elections by filing federal-court suits for violations of Title IV.” Calhoon, 379 U.S. at 140, 85 S.Ct. at 296.

Plaintiffs’ argue that the exclusivity provision is inapplicable, since they are not “challenging an election already conducted.” 29 U.S.C. § 483 (emphasis added). Rather, plaintiffs contend, they merely seek validation of the October, 1993 election. The court in Molina v. Union De Trabajadores De Muelles Y Ramas Anexas, Local 1740 faced a similar argument on similar facts. 762 F.2d 166 (1st Cir.1985). There, plaintiffs complained that the union activated a voting eligibility rule for improper motives and sought validation of an election that had been set aside. Id. at 167. The court addressed the same argument that plaintiffs advance here:

We recognize that appellants’ request for validation of the first election arguably is not a “challenge” to that election. We doubt that appellants escape the bar of section 403 with such a request, however, because their complaint seeks indirectly to overturn the later two elections and it directly contests the outcome of the first election insofar as it seeks to reverse the union’s invalidation of it.

Id. at 168.

The court finds that the reasoning set forth in Molina is applicable in the present case. Local 171 challenges the October, 1993 election to the extent that it seeks to reverse the General Election Board’s invalidation of that election.

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871 F. Supp. 258, 1994 U.S. Dist. LEXIS 18862, 1994 WL 724893, Counsel Stack Legal Research, https://law.counselstack.com/opinion/chauffeurs-teamsters-helpers-local-union-no-171-v-international-vawd-1994.