International Longshoremen Association, Local 1413-1465 v. Massachusetts Commission Against Discrimination

CourtMassachusetts Appeals Court
DecidedApril 3, 2024
DocketAC 23-P-83
StatusPublished

This text of International Longshoremen Association, Local 1413-1465 v. Massachusetts Commission Against Discrimination (International Longshoremen Association, Local 1413-1465 v. Massachusetts Commission Against Discrimination) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
International Longshoremen Association, Local 1413-1465 v. Massachusetts Commission Against Discrimination, (Mass. Ct. App. 2024).

Opinion

NOTICE: All slip opinions and orders are subject to formal revision and are superseded by the advance sheets and bound volumes of the Official Reports. If you find a typographical error or other formal error, please notify the Reporter of Decisions, Supreme Judicial Court, John Adams Courthouse, 1 Pemberton Square, Suite 2500, Boston, MA, 02108-1750; (617) 557- 1030; SJCReporter@sjc.state.ma.us

23-P-83 Appeals Court

INTERNATIONAL LONGSHOREMEN ASSOCIATION, LOCAL 1413-1465 vs. MASSACHUSETTS COMMISSION AGAINST DISCRIMINATION & another.1

No. 23-P-83.

Bristol. October 6, 2023. – April 3, 2024.

Present: Green, C.J., Milkey, & Grant, JJ.

Anti-Discrimination Law, Sex. Employment, Discrimination. Massachusetts Commission Against Discrimination. Labor, Fair representation by union. Administrative Law, Substantial evidence. Damages, Under anti-discrimination law, Emotional distress. Emotional Distress. Labor, Federal preemption. Jurisdiction, Federal preemption. Federal Preemption. Practice, Civil, Judgment on the pleadings, Waiver. Waiver.

Civil action commenced in the Superior Court Department on July 22, 2020.

The case was heard by Renee P. Dupuis, J., on motions for judgment on the pleadings.

Scott W. Lang for the plaintiff. Peter M. Mimmo for Massachusetts Commission Against Discrimination. The following submitted briefs for amici curiae:

1 April L. Robar. 2

Andrea Joy Campbell, Attorney General, & Jessica Rahmoune & Douglas S. Martland, Assistant Attorneys General, for the Commonwealth. James A.W. Shaw & Ryan M. Quinn for Massachusetts AFL-CIO. Joseph L. Sulman for Massachusetts Employment Lawyers Association.

MILKEY, J. Women have been employed at the Port of New

Bedford for years. However, their work there traditionally was

confined to certain jobs that were viewed as low-level. Over

time, some women began to seek other positions at the port,

including that of forklift operator, a position that

traditionally had been staffed only by men. Such efforts were

rebuffed by the International Longshoremen Association, Local

1413-1465 (union), which ran the hiring process through which

workers were selected for available positions. In 2009, April

Robar filed a complaint with the Massachusetts Commission

Against Discrimination (commission) alleging that the union had

engaged in sex discrimination against her.

Specifically, Robar alleged that she was passed over for

work as a forklift operator in favor of men who not only were

less qualified than she was, but who -- unlike her -- lacked a

mandatory qualification for the position. When given the

opportunity to respond, the union's then-treasurer (later

president and business agent), Edmond Lacombe, supplied a

written statement that proved unhelpful to the union's defense.

Specifically, among other things, he recounted that the women 3

who were hired for the traditionally female positions "did not

complain"; rather, "[t]hey, more or less, knew their place when

work was issued and accepted the outcome."

Following an adjudicatory hearing, a hearing officer found

that the union had discriminated against Robar based on her sex.

The full commission upheld the hearing officer's decision, as

did a Superior Court judge. In this further appeal, the union

challenges the commission's decision on the merits and

additionally argues that it is preempted by various Federal

labor laws.2 We affirm.

Background.3 The freight terminal in New Bedford Harbor is

operated by Maritime International, Inc. (Maritime). Maritime

and the union entered into a collective bargaining agreement

(CBA) under which the union was given the role of referring

interested workers for available work. Strictly speaking,

Maritime retained final hiring rights, but, as a practical

matter, it was the union that selected who would be hired among

the union members and nonunion workers who would show up at the

docks each morning to fill open positions. This process is a

2 We acknowledge the amicus letter submitted by the Commonwealth and the amicus briefs submitted by the Massachusetts AFL-CIO and the Massachusetts Employment Lawyers Association.

3 Our recitation of the facts is based on the findings made by the hearing examiner. 4

form of what is known as a "hiring hall," and specifically is

known as a "shape up" in the maritime industry. At the shape

ups, union members were selected first based on the order of

their seniority in the union, and according to the testimony of

union members, only then would nonunion workers be hired for the

remaining jobs. As of 2009, there were no female members of the

union.

The CBA included some specific requirements for different

dock positions. For example, consistent with regulations issued

by the Occupational Safety and Health Administration (OSHA), see

29 C.F.R. § 1910.178(l), all forklift operators were required to

have a forklift safety certificate issued by Maritime.

In 2004, Robar started working at the Maritime terminal as

a nonunion "wrapper/stamper" on fish boats. That job involved

wrapping pallets of fish in plastic sheeting and stamping boxes

of fish. It was viewed as an undesirable position that

typically was staffed only by women. The union selected men for

such positions only if there were not enough women to fill the

positions.

Over time, the types of boats serviced at the terminal

shifted. The number of fish boats decreased, leaving available

work mostly confined to fruit boats, which did not need

wrapper/stampers. Robar and other workers testified that they 5

had never seen any women hired for off-loading the fruit boats.

There was no evidence to the contrary.

Because there were fewer available jobs on fish boats, and

in order to seek better working conditions, Robar sought work at

the terminal as a forklift operator. She already had received

an OSHA-mandated forklift safety certificate from a previous

employer, and she obtained one from Maritime as well.4 In her

spare time, she also availed herself of the opportunity to

undergo informal practical training to learn how to operate

forklifts on the docks. There was testimony from a union member

that Robar did an "outstanding job" in operating a forklift on

the docks.

Despite Robar's qualifications and efforts to obtain work

as a forklift operator, she was denied the position five

separate times by the union officials running the shape up,

4 In the wake of security concerns raised by the attacks of September 11, 2001, dock workers also were required to obtain a "transportation worker identification credential" (known as a TWIC card). In fact, Robar went through proper procedures and obtained a TWIC card. The union points out that given problems that many dock workers faced in obtaining TWIC cards, the requirement that they hold one was softened so as to allow non- cardholders to continue working without one so long as the ratio of TWIC cardholders to non-cardholders was at least 1:5. Thus, although Robar's being hired did not depend on her holding a TWIC card, her having one was, if anything, a net plus to the union. After all, the union had an express obligation under the CBA to "ensure that a sufficient number of employees hired possess a TWIC as required by the Department of Homeland Security." 6

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