International Brotherhood of Teamsters v. Teamsters Local Union 714, Machinery Scrap Iron, Metal & Steel Chauffeurs

109 F.3d 846
CourtCourt of Appeals for the Second Circuit
DecidedMarch 17, 1997
DocketNo. 892, Dockets 96-6235, 96-9103
StatusPublished
Cited by1 cases

This text of 109 F.3d 846 (International Brotherhood of Teamsters v. Teamsters Local Union 714, Machinery Scrap Iron, Metal & Steel Chauffeurs) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
International Brotherhood of Teamsters v. Teamsters Local Union 714, Machinery Scrap Iron, Metal & Steel Chauffeurs, 109 F.3d 846 (2d Cir. 1997).

Opinion

PER CURIAM.

Orders .of the United States District Court for the Southern District of New York, David N. Edelstein, Judge, dated August 22, 1996, and August 29, 1996, enjoined Local Unions 745 and 714 of the International Brotherhood of Teamsters (the “Locals”) to cooperate with the emergency trusteeship imposed upon them by their parent union, and to refrain from challenging the trusteeships in any other court. The Locals appeal these injunctions. We have jurisdiction under 28 U.S.C. § 1292(a)(1). The only serious issue raised in these appeals is the assertion by the district court of exclusive jurisdiction over these actions. We readily conclude that the decision to enjoin the Locals to cooperate with the trusteeships was not an abuse of discretion.

Background

These appeals, like numerous others in the recent past, arise out of the action filed in 1988 by the United States (“the .Government”) under the civil remedies provision of the Racketeer Influenced and Corrupt Organizations Act (“RICO”) 18 U.S.C. § 1964, against, inter alia, the International Brotherhood of Teamsters (“the IBT”). On March 14,1989, Judge Edelstein approved a consent decree resolving the Government’s claims against the IBT. In the first phase of the program set up by the decree, three officers were appointed by the court to investigate corruption and other misconduct and to supervise remedial actions. Following the union’s first direct election, the officers were replaced by an Independent Review Board (“IRB”) which continued the process of investigation and reform. The district court retained exclusive jurisdiction over matters arising under the consent decree.

The IRB is empowered by the consent decree to investigate allegations of corruption in the IBT. The IRB prepares investigative reports concerning various matters including recommendations that any IBT affiliated body be placed in trusteeship. The reports, which are given to the appropriate IBT entity, set deadlines of up to 90 days for the union to respond. The IRB retains authority to supervise the IBT’s resolution of the matters raised by the reports. Rules of the IRB reserve “exclusive jurisdiction to decide any and all issues relating to the purpose, operation, and authority of the IRB and the interpretation of [the IRB] Rules” to the United States District Court for the Southern District of New York.

Following entry of the consent decree, the Government sought an order under the All Writs Act, 28 U.S.C. § 1651(a), enjoining all IBT members and affiliates from litigating issues arising under the consent decree in any forum other than the Southern District [848]*848of New York. On January 17, 1990, the district court issued such an. .injunction, which was affirmed by this court. United States v. Int’l Bhd. of Teamsters, 728 F.Supp. 1032 (S.D.N.Y.), aff'd, 907 F.2d 277 (2d Cir. 1990) (“All Writs Order").

The Local 7^.5 Action

On August 5, 1996, the IRB issued a report to IBT President Carey, detailing wrongdoing at IBT Local 745 in Dallas, Texas, and recommending that the IBT impose a trusteeship over the Local. The report discussed illegal loans, nepotism, favoritism in work assignments, and conflicts of interest arising from business dealings between union officers and Local 745 employers. The IRB requested a written report from the union setting forth actions planned in accordance with the board’s recommendations.

On August 20, IBT President Carey imposed an emergency trusteeship upon Local 745. The Local’s officers resisted the trusteeship, and on August 21 the IBT filed an application in the Southern District of New York, seeking a declaratory judgment that the emergency trusteeship was an appropriate response to the IRB recommendation. The IBT also filed a complaint seeking declaratory and injunctive relief enforcing the terms of the trusteeship. The district court entered a temporary restraining order pending a hearing on the IBT’s motion.

Also on August 21, Local 745 filed an action in the Northern District of Texas and moved for a temporary restraining order enjoining the imposition ' of the trusteeship. The district court in Texas denied the motion pending receipt of responsive papers from the IBT. A second motion brought by the Local, seeking an injunction preventing the IBT from taking any action against the Local until the Texas court ruled on the motion for a temporary restraining order, was also denied. On August 27, following the order of the New York court discussed next, the district court in Texas denied the application for a temporary restraining order.

On August 22, 1996, the district court in the Southern District of New York conducted a hearing on the IBT’s motion for a preliminary injunction. From the bench, the court granted a two-part injunction (1) enforcing the trusteeship, and (2) enjoining Local 745 from pursuing any legal action in connection with the trusteeship in any other court. This oral order was followed by an Amended Opinion and Order dated August 30, 1996. Local 745 appeals the injunctions.

The Local 7H Action

The IRB, on August 5, 1996, had also presented a report to IBT President Carey, detailing wrongdoing at IBT Local 714 in Berwyn, Illinois, and recommending that the Local be placed in trusteeship. The allegations included favoritism, the admission of ineligible individuals as members, and the existence of sham contracts. The IRB asked for a response from the IBT within two weeks.

Three days after the receipt of the report, President Carey imposed an emergency trusteeship upon Local 714. That same day, the IBT brought an action in the Northern District of Illinois seeking an injunction requiring the Local to cooperate with the trusteeship. A temporary restraining order issued on August 9,1996.

On August 23, 1996, the district court in the Southern District of New York ordered the case transferred, and enjoined IBT from pursuing the Local 714 action in any other court. The court in the Northern District of Illinois promptly transferred the matter to New York. Local 714 then moved to dismiss or, in the alternative, retransfer the action. The Local further claimed that the preliminary injunction should be denied because the IBT was unlikely to succeed on its claims. In an Opinion and Order dated August 29, 1996, the district court denied the motion to dismiss or retransfer, and granted the preliminary injunction sought by the IBT. Local 714 appeals this decision. By order of this court, the appeals of Locals 714 and 745 were consolidated on September 13, 1996.

Exclusive Jurisdiction

We affirm the decisions below on a single issue without establishing a general jurisdictional rule applicable to any legal action in which a subordinate entity challenges [849]*849the IBT’s imposition of remedial measures in the wake of a recommendation from the IRB.

The appellants raise specific challenges to the IRB reports recommending that President Carey impose trusteeships.

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109 F.3d 846, Counsel Stack Legal Research, https://law.counselstack.com/opinion/international-brotherhood-of-teamsters-v-teamsters-local-union-714-ca2-1997.