International Union, United Automobile, Aerospace, & Agricultural Implement Workers v. Brock

477 U.S. 274, 106 S. Ct. 2523, 91 L. Ed. 2d 228, 1986 U.S. LEXIS 116, 4 Fed. R. Serv. 3d 1067, 54 U.S.L.W. 4764, 122 L.R.R.M. (BNA) 2657
Supreme Court of the United States·Decided June 25, 1986·No. 84-1777·Published·Cited by 481 cases

Opinions

Justice Marshall

delivered the opinion of the Court.

This suit was brought by the International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW), and several of its members challenging the Secretary of Labor’s interpretation of the eligibility provisions of the Trade Act of 1974, 88 Stat. 1978, 19 U. S. C. [277]*277§ 2101, which provides benefits to workers laid off because of competition from imports. The issues presented here are whether the Union has standing to sue in federal court on behalf of its affected members and whether such a suit can be maintained without the joinder as defendants of the state agencies that administer the benefit program in question.

I — I

To aid workers who have lost their jobs because of import competition, the Trade Act of 1974 established a program of trade readjustment allowance (TRA) benefits as a supplement to state unemployment insurance benefits. 19 U. S. C. §2291. Under the Act’s scheme, a group of workers, their union, or some other authorized representative may petition the Secretary of Labor to certify that their firm has been adversely affected by imports. §§2271-2273. If the Secretary issues a certificate of eligibility for such a group, workers within that group who meet certain standards of individual eligibility may then apply for and receive TRA benefits. These benefits are funded entirely by the Federal Government, as is the cost of administering the program.

While the Secretary of Labor cannot delegate his certification duties, the Act does permit him to contract out the job of making individual eligibility determinations to the state agencies that administer state unemployment insurance programs. The Secretary has in fact entered into such agreements with unemployment insurance agencies in each State and in the District of Columbia and Puerto Rico. Pursuant to the agreements, each of these “cooperating Stat[e] agencies,” § 2311(a), becomes an “agent of the United States,” § 2313(a), charged with processing applications and using federal funds to pay TRA benefits to individuals eligible under the Act. Review of eligibility decisions by these agencies is to be “in the same manner and to the same extent as determinations under the applicable State law and only in that [278]*278manner and to that extent.” § 2311(d). In making these eligibility determinations, however, state authorities are bound to apply the relevant regulations promulgated by the Secretary of Labor and the substantive provisions of the Act. 29 CFR § 91.51(c) (1985).

To qualify for TRA benefits under the Act, a worker must have “had, in the 52 weeks immediately preceding . . . separation, at least 26 weeks of employment at wages of $30 or more a week in adversely affected employment with a single firm or subdivision of a firm.” 19 U. S. C. §2291(2) (1976 ed.). In a 1975 policy handbook, the Secretary advised the state agencies that they should not count toward these 26 weeks

“[p]eriods in which service is not being performed, such as leave of absence, sick or annual leave or vacation leave, and periods in which service is being performed for other than the adversely affected employer, such as military service, temporary loan or detail to another employer, or work for another employer while attached to the adversely affected employer . . . .” App. 85.

These guidelines were superseded in August 1981 by the Omnibus Budget Reconciliation Act of 1981 (OBRA), Pub. L. 97-35, 95 Stat. 357, which amended the Trade Act to provide that “leave for purposes of vacation, sickness, injury, maternity, or inactive duty or active duty military service for training” is to be included in determining an individual’s period of employment with an adversely affected firm. 19 U. S. C. § 2291(a)(2)(A). The effect of this amendment, however, was limited to TRA benefits “payable for weeks of unemployment which begin after September 30, 1981.” OBRA, § 2514(a)(2)(B), 95 Stat. 889, note following 19 U. S. C. §2291.

Shortly after the passage of the OBRA, petitioners, the UAW and 11 of its members — some of whom had been denied benefits for weeks of employment before October 1, 1981, because of the interpretation of § 2291 in the 1975 handbook and [279]*279some of whom were defending the award of benefits against appeals by their respective state agencies — filed this suit in District Court against the Secretary of Labor. Claiming that the Secretary’s interpretation had been incorrect and, to the extent that it related to military leave, in violation of the Veterans’ Employment and Readjustment Act of 1972, 38 U. S. C. §2013, and the Vietnam Era Veterans’ Readjustment Assistance Act of 1974, 38 U. S. C. §§2014, 2024, petitioners sought a declaration that the interpretation was improper and an injunction requiring the Secretary both to notify all cooperating state agencies of the invalidity of the handbook and to direct those agencies to review and reprocess all cases in which TRA benefits had been denied.

On cross-motions for summary judgment, the District Court first rejected the Secretary’s argument that § 2311(d), which makes entitlement determinations reviewable only “in the same manner and to the same extent as determinations under the applicable State law,” precluded federal jurisdiction over the action. International Union, United Automobile, Aerospace and Agricultural Implement Workers of America v. Donovan, 568 F. Supp. 1047, 1050-1052 (DC 1983). It noted:

“In the typical case the Act envisions that a disappointed applicant for TRA benefits appeals to the state court the administering agency’s application of the pertinent guidelines or regulations to the facts of his case. The instant case, however, is atypical. Here, plaintiffs allege that the guidelines themselves are invalid; they do not contest the particulars of the application of the guidelines to the facts of individual cases.” Id., at 1050.

On the merits of the complaint, the court held that the 1975 guidelines were indeed inconsistent with the Trade Act and the Veterans’ Readjustment Assistance Act of 1972. It therefore ordered the Secretary to notify all cooperating state agencies of the Act’s proper construction and to direct those agencies to process anew, applying the proper eligibil[280]*280ity standards, any TRA claims wrongfully denied as a result of the 1975 guidelines.

Without reaching the merits, a divided panel of the Court of Appeals reversed. 241 U. S. App. D. C. 106, 746 F. 2d 839 (1984). The court first noted that the UAW “is not an appropriate representative of those TRA claimants who were not its members,” id., at 109, 746 F. 2d, at 842, and that, at this stage of the proceedings, it would be “impermissible” to treat the suit as a class action on behalf of all disappointed claimants, id., at 108, 746 F.

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International Union, United Automobile, Aerospace, & Agricultural Implement Workers v. Brock, 477 U.S. 274, 106 S. Ct. 2523, 91 L. Ed. 2d 228, 1986 U.S. LEXIS 116, 4 Fed. R. Serv. 3d 1067, 54 U.S.L.W. 4764, 122 L.R.R.M. (BNA) 2657 (1986).

477 U.S. 274 (International Union, United Automobile, Aerospace, & Agricultural Implement Workers v. Brock) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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