James v. United Furniture Workers Local 89262

CourtDistrict Court, N.D. California
DecidedAugust 16, 2021
Docket3:21-cv-03893
StatusUnknown

This text of James v. United Furniture Workers Local 89262 (James v. United Furniture Workers Local 89262) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James v. United Furniture Workers Local 89262, (N.D. Cal. 2021).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 ANTHONY ALEXANDER JAMES, Case No. 21-cv-03893-JCS

8 Plaintiff, ORDER REGARDING MOTION TO 9 v. DISMISS

10 UNITED FURNITURE WORKERS Re: Dkt. No. 4 LOCAL 89262, 11 Defendant.

12 13 I. INTRODUCTION 14 Plaintiff Anthony Alexander James brought this action asserting various clams against 15 Defendant United Furniture Workers Local 89262 (the “Union”) related to the Union’s 16 representation of James during his employment and subsequent termination at Sealy Tempur- 17 Pedic (“Sealy”).1 The Union now moves to dismiss for failure to state a claim under Rule 12(b)(6) 18 of the Federal Rules of Civil Procedure. For the reasons discussed below, the Union’s motion is 19 GRANTED, and James’s complaint is DISMISSED with leave to amend no later than September 20 24, 2021.2 21 II. BACKGROUND 22 A. Procedural History 23 James initially filed this action pro se in the California Superior Court for Alameda 24 County. See generally Compl. (dkt. 1-1). He asserted state law claims including negligence, 25 fraud, and race discrimination under California’s Fair Employment and Housing Act (“FEHA”). 26 1 James’s employer was named in a previous lawsuit as “Tempur Sealy International, Inc.” 27 Resolving which name is correct is not material to the outcoming of the present motion. 1 Id. at 6–7, 10–12. The Union removed the case to federal court on May 24, 2021. Not. of 2 Removal (dkt. 1). 3 B. James’s Complaint 4 Because a plaintiff’s factual allegations are generally taken as true on a motion under Rule 5 12(b)(6), this section summarizes the allegations of James’s complaint as if true. Nothing in the 6 order should be construed as resolving any issue of fact that might be disputed at a later state of 7 the case. 8 James, an “African American male,” Compl. at 10,3 worked as a driver for Sealy, a 9 mattress business, from 2011 until he was terminated by Sealy in 2016. Compl. at 9–10. The 10 Union represented employees at Sealy who paid union dues. Id. Some time prior to James’s 11 termination in 2016, Sealy forged documents that suggested that he had been suspended from his 12 job at Sealy three separate times—suspensions that had not actually occurred. Id. at 9, 11. On the 13 basis of the inaccurate information in the forged documents and James having clocked in three 14 minutes early on March 22, 2016, Sealy terminated James. Id. James alerted the Union of his 15 termination and the forged documents, and the Union informed James that it would file a 16 grievance on James’s behalf. Id. at 9. Three months after James’s termination, the Union notified 17 James that they would not be able to help him; the Union based this determination on the forged 18 documentation indicating that James was suspended three times. Id. 19 James subsequently reached out to the National Labor Relations Board (“NLRB”) to seek 20 help. Id. The NLRB contacted the Union, and a meeting was set up to review James’s personnel 21 files, at which time the Union became aware that the documentation of James’s suspensions 22 lacked necessary signatures. Id. However, James alleges that the Union was aware of the “act” 23 prior to this meeting. Id. at 11. James requested that the Union direct Sealy to reinstate him in his 24 previous position and compensate him with back pay. Id. at 9. Instead, James was offered less 25

26 3 James’s complaint consists of multiple documents (including state court forms, a document labeled “attachment” that contains factual allegations and a demand for payment, and copies of 27 several emails and other supporting documentation) without any clear page or exhibit numbering. 1 money than he was requesting and was asked to agree to a “Last Chance contract” and drug 2 testing. Id. James declined the deal and asked the Union to take his grievance to arbitration. Id at 3 9–10. James was then terminated. Id. at 10. 4 In 2019, James sued Sealy. Id.; see James v. Tempur Sealy Int’l, Inc., No. 18-cv-07130-SI 5 (N.D. Cal.). During that litigation, which eventually settled,4 James and his attorneys discovered 6 that the Union and Sealy corresponded about James’s three forged suspension documents prior to 7 James’s termination. Compl. at 9. James alleges that “non-African American[s] . . . have options 8 . . . based on [the] union employee contract” that were not accorded to James, including filing 9 grievances, meeting with union representatives about disciplinary actions, and securing union 10 witnesses to disciplinary actions. Id. at 11. James further alleges that Sealy fired him based on 11 information that the Union knew was false and without the Union taking his case to arbitration, 12 none of which would have happened if James was “non-African American.” Id. According to 13 James’s complaint, a “majority of the African American driver[s] [felt] discrimination,” and there 14 was at least one other African American driver who was terminated by Sealy under similar 15 circumstances with the Union’s knowledge. Id. at 12. 16 In emails and other documents attached to James’s complaint, Union personnel and 17 attorneys state that although Sealy acknowledged wrongdoing and fired a supervisor who forged at 18 least one signature, negotiations with Sealy were undermined by confrontational interactions 19 between James and other Sealy employees, and the Union intended to withdraw its grievance if 20 James did not accept a $10,000 settlement offer. Id. at 14–21. Viewing the complaint in the light 21 most favorable to James, the Court understands the inclusion of those documents as alleging that 22 they existed, but not as alleging the truth of their contents—in particular, for the purpose of this 23 motion to dismiss, the Court does not take as true the Union’s statements that James acted 24 confrontationally. 25 Various portions of James’s complaint differ as to the claims he is asserting. A state court 26

27 4 The undersigned magistrate judge served as the settlement judge for the previous case against 1 civil cover sheet indicates that he is asserting claims for unfair business practices, defamation, 2 fraud, and wrongful termination. Id. at 3. The first page of his state court form complaint 3 indicates that he is asserting a contract claim. Id. at 4. Other portions of the form complaint 4 indicates that James is asserting a fraud claim based on “Intentional or Negligent 5 Misrepresentation . . . On Wrongful Termination” and false promise, and a negligence claim. Id. 6 at 6–8. The narrative portion of James’s complaint asserts a claim for race discrimination under 7 FEHA. Id. at 10–11. Near the end of the narrative portion of his complaint, James refers to 8 claims for unfair business practices, misrepresentation, race discrimination, and negligence. Id. at 9 12. James attaches a notice of right to sue issued by the Equal Employment Opportunity 10 Commission (“EEOC”) on January 21, 2021. Id. at 22. James states that he would like to settle 11 his claims for $200,000. Id. at 12. 12 C. The Union’s Motion to Dismiss 13 The Union moves to dismiss James’s complaint on the basis that his complaint is factually 14 vague, and that the claims which are identifiable are preempted by federal law and barred by the 15 statute of limitations. See Mot. (dkt. 4). 16 The Union argues that all of James’s claims are preempted by the Union’s duty of fair 17 representation under section 9 of the National Labor Relations Act (“NLRA”). Id. at 5 (citing 29 18 U.S.C. § 159). The Union cites Supreme Court precedent holding that a union’s duty of fair 19 representation requires it “‘to represent all members . . .

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Bluebook (online)
James v. United Furniture Workers Local 89262, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-v-united-furniture-workers-local-89262-cand-2021.