International Union, United Automobile, Aerospace & Agricultural Implement Workers v. National Right to Work Legal Defense & Education Foundation, Inc.

590 F.2d 1139, 192 U.S. App. D.C. 23
CourtCourt of Appeals for the D.C. Circuit
DecidedNovember 17, 1978
DocketNos. 77-1739, 77-1766 and 77-1767
StatusPublished
Cited by56 cases

This text of 590 F.2d 1139 (International Union, United Automobile, Aerospace & Agricultural Implement Workers v. National Right to Work Legal Defense & Education Foundation, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals for the D.C. Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
International Union, United Automobile, Aerospace & Agricultural Implement Workers v. National Right to Work Legal Defense & Education Foundation, Inc., 590 F.2d 1139, 192 U.S. App. D.C. 23 (D.C. Cir. 1978).

Opinion

Opinion for the court filed by Circuit Judge TAMM.

TAMM, Circuit Judge:

This is an appeal from a decision in which the United States District Court for the District of Columbia held that the second proviso to section 101(a)(4) of the Labor-Management Reporting and Disclosure Act of 1959 (LMRDA), 29 U.S.C. § 411(a)(4) (1976), is unconstitutional as applied to the litigation program of the National Right to Work Legal Defense and Education Foundation, Inc., and that section 203(b)(1) of the LMRDA, 29 U.S.C. § 433(b)(1) (1976), does not afford a private right of action. We conclude that the second proviso to section 101(a)(4) of the LMRDA, as properly construed, does not apply to the legitimate activity of a bona, fide, independent legal aid association, and we remand for further proceedings. We agree with the district court that no private right of action exists for judicial enforcement of section 203(b)(1) of the LMRDA.

I

The National Right to Work Legal Defense and Education Foundation, Inc. [27]*27(Foundation), was established in 1968 by the Board of Directors of the National Right to Work Committee (Committee).1 The Committee itself is a tax-exempt, nom profit organization that opposes “compulsory unionism” through various activities, including educational projects and support of “right to work” legislation.2 The Foundation was created as a tax-exempt, non-profit corporation with the principal purpose of providing financial assistance to workers who bring lawsuits attacking features of “compulsory unionism.”

“Compulsory unionism” is an aspect of union-security agreements. In the collective bargaining process, most labor organizations seek union security through agreements with employers that condition employment upon some type of “compulsory membership” in the union. See generally B. Taylor & F. Witney, Labor Relations Law 317-32 (2d ed. 1975). Although the Labor Management Relations Act, 1947, outlawed the closed shop, which required a worker to join a union before qualifying for a job, § 101, 61 Stat. 140, permissible forms of union security include the union shop, which requires an employee to become a union member within a specified time after being hired, and the agency shop, which requires an employee to pay a service fee to the union equivalent to union dues and initiation fees. See Abood v. Detroit Board of Education, 431 U.S. 209, 217 n.10, 97 S.Ct. 1782, 52 L.Ed.2d 261 (1977). By permitting forms of “compulsory unionism” less onerous than the closed shop, and providing that union membership may require the payment of periodic dues and initiation fees, Congress recognized the unfairness of permitting “free riders” to share in the benefits of what the union accomplished through collective bargaining. NLRB v. General Motors Corp., 373 U.S. 734, 740-43, 83 S.Ct. 1453, 10 L.Ed.2d 670 (1963); see National Labor Relations Act, § 8(a)(3), 29 U.S.C. § 158(a)(3) (1976).3 At its core, compulsory unionism refers to mandatory payment by employees of union dues and initiation fees. NLRB v. General Motors Corp., 373 U.S. at 742, 83 S.Ct. 1453.

Since its creation, the Foundation has supported numerous test cases brought against labor organizations by workers who attack union dues obligations.4 The Foun[28]*28dation has financed lawsuits, provided counsel, and filed briefs as amicus curiae. See Brief for Plaintiffs-Appellants at 34-38; see also Joint Appendix (J.A.) I at 6-14 (Second Amended Complaint). One of the suits supported by the Foundation resulted in the recent Supreme Court decision Abood v. Detroit Board of Education, 431 U.S. 209, 97 S.Ct. 1782, 52 L.Ed.2d 261, which held that a union cannot constitutionally use money paid by employees pursuant to an agency shop agreement between the union and a local governmental employer for political purposes that the employees do not wish to support and that are not germane to the union’s duties as a collective bargaining representative. Id. at 232-37, 97 S.Ct. 1782. See generally Comment, The Regulation of Union Political Activity: Majority and Minority Rights and Remedies, 126 U.Pa.L.Rev. 386, 414-20 (1977).

il

In May 1973, a group of national and local labor organizations (the unions)5 sued the Foundation and the Committee in the United States District Court for the District of Columbia. In their first cause of action, the unions sought a declaratory judgment that the Foundation was violating section 101(a)(4) of the LMRDA, 29 U.S.C. § 411(a)(4) (1976),6 by “financing, encouraging and participating in (other than as a party) suits brought by members of labor organizations and by employees against labor organizations with funds provided by interested employers or employer associations and on their behalf.” J.A. I at 18. The unions sought a permanent injunction prohibiting the Foundation from continuing these practices, and prohibiting the Committee from assisting the Foundation in [29]*29such litigation. The unions also asked for compensatory and exemplary damages.

In their second cause of action, the unions requested a declaratory judgment that the Foundation and Committee violated section 203(b)(1) of the LMRDA, 29 U.S.C. § 433(b)(1) (1976),7 by failing to file statements with the Secretary of Labor reporting agreements with contributing employers concerning persuasion of employees. They sought an injunction requiring the Foundation and Committee to file such reports. The unions also sought exemplary damages. J.A. I at 19-20.

The Foundation’s and the Committee’s motion to dismiss the unions’ complaint for failure to state a cause of action was denied. International Union, UAW v. National Right to Work Legal Defense and Education Foundation, 366 F.Supp. 46 (D.D.C.1974).8 Subsequently, the Foundation and the Committee asserted a number of defenses and sought, in a counterclaim, a declaratory judgment that sections 101(a)(4) and 203(b)(1) of the LMRDA would be unconstitutional if applied to the Foundation’s litigation program. J.A. I at 82-86.

During discovery proceedings in the district court, the unions requested that the Foundation and Committee disclose the names and addresses of all employers and businesses that contributed to the Foundation during 1972. Id. at 141. The unions also requested that the Foundation reveal contributions by companies whose officers or employees were members of the Foundation’s publicly identified Advisory Council. Id. at 46, 144. The Foundation refused to disclose the identities of any contributors, asserting constitutional privileges against disclosure and contending that disclosure would result in reprisals against contributors.

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Bluebook (online)
590 F.2d 1139, 192 U.S. App. D.C. 23, Counsel Stack Legal Research, https://law.counselstack.com/opinion/international-union-united-automobile-aerospace-agricultural-implement-cadc-1978.