Local No. 82, Furniture & Piano Moving, Furniture Store Drivers, Helpers, Warehousemen & Packers v. Crowley

467 U.S. 526, 104 S. Ct. 2557, 81 L. Ed. 2d 457, 1984 U.S. LEXIS 107
CourtSupreme Court of the United States
DecidedAugust 2, 1984
Docket82-432
StatusPublished
Cited by215 cases

This text of 467 U.S. 526 (Local No. 82, Furniture & Piano Moving, Furniture Store Drivers, Helpers, Warehousemen & Packers v. Crowley) is published on Counsel Stack Legal Research, covering Supreme Court of the United States primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Local No. 82, Furniture & Piano Moving, Furniture Store Drivers, Helpers, Warehousemen & Packers v. Crowley, 467 U.S. 526, 104 S. Ct. 2557, 81 L. Ed. 2d 457, 1984 U.S. LEXIS 107 (1984).

Opinions

Justice Brennan

delivered the opinion of the Court.

The Labor-Management Reporting and Disclosure Act of 1959 (LMRDA or Act), 73 Stat. 522, as amended, 29 U. S. C. §401 et seq., was Congress’ first major attempt to regulate the internal affairs of labor unions. Title I of the Act provides a statutory “Bill of Rights” for union members, including various protections for members involved in union elections, with enforcement and appropriate remedies available in district court. Title IV, in contrast, provides an elaborate postelection procedure aimed solely at protecting union democracy through free and democratic elections, with primary responsibility for enforcement lodged with the Secretary of Labor. Resolution of the question presented by this case requires that we address the conflict that exists between the separate enforcement mechanisms included in these two Titles. In particular, we must determine whether suits alleging violations of Title I may properly be maintained in district court during the course of a union election.

The Court of Appeals approved a preliminary injunction issued by the District Court that enjoined an ongoing union [529]*529election and ordered the staging of a new election pursuant to procedures promulgated by the court. After reviewing the complex statutory scheme created by Congress, we conclude that such judicial interference in an ongoing union election is not appropriate relief under § 102 of Title I, 29 U. S. C. § 412. We therefore reverse the Court of Appeals.

Local No. 82, Furniture and Piano Moving, Furniture Store Drivers, Helpers, Warehousemen, and Packers (Local 82) represents approximately 700 employees engaged in the furniture moving business in the Boston, Mass., area.1 The union is governed by a seven-member executive board whose officers, pursuant to § 401(b) of the LMRDA, 29 U. S. C. § 481(b), must be chosen by election no less than once every three years. These elections, consistent with the executive board’s discretion under the union’s bylaws and constitution, have traditionally been conducted by mail referendum balloting. The dispute giving rise to the present case stems from the union election that was regularly scheduled for the last two months of 1980.

On November 9, 1980, Local 82 held a meeting to nominate candidates for positions on its executive board. The meeting generated considerable interest, in part because dissident members of the union were attempting to turn the incumbent union officials out of office. Two aspects of the controversial meeting are especially important for present purposes. First, admission to the meeting was restricted to those members who could produce a computerized receipt showing that their dues had been paid up to date. Several union members, including respondent Jerome Crowley, were prohibited from entering the meeting because they did not have such dues receipts in their possession. Second, during the actual [530]*530nominations process, there was disagreement relating to the office for which respondent John Lynch had been nominated. At the close of nominations, petitioner Bart Griffiths, the union’s incumbent secretary-treasurer, declared himself the only candidate nominated for that office; at the same time, he included Lynch among the candidates selected to run for union president.

Several dissatisfied members of the union, now respondents before this Court,2 filed a protest with the union. On November 20, their protest was denied by Local 82.3 Election ballots were thereafter distributed to all members of the union, who were instructed to mark and return the ballots by mail so that they would arrive in a designated post office box by 9 a. m. on December 13, 1980, at which time they were scheduled to be counted. Respondent Lynch’s name appeared on the ballot as a candidate for president, and not for secretary-treasurer.

On December 1, 1980, after the distribution of ballots had been completed, the respondents filed this action in the United States District Court for the District of Massachusetts. They alleged, inter alia, that Local 82 and its officers had violated several provisions of Title I of the LMRD A, and sought a preliminary injunction. In particular, the respondents claimed that restricting admission to the nominations meeting to those members who could produce computerized dues receipts violated their “equal rights ... to nominate [531]*531candidates [and] to attend membership meetings” under § 101(a)(1) of the Act,4 as well as their right freely to express views at meetings of the union under § 101(a)(2) of the Act.5 They also alleged that the union and its officers had violated § 101(a)(1) by failing to recognize respondent Lynch as a candidate for secretary-treasurer.6

“Equal Rights. — Every member of a labor organization shall have equal rights and privileges within such organization to nominate candidates, to vote in elections or referendums of the labor organization, to attend membership meetings and to participate in the deliberations and voting upon the business of such meetings, subject to reasonable rules and regulations in such organization’s constitution and bylaws.” 73 Stat. 522, 29 U. S. C. § 411(a)(1).

[532]*532After preliminary papers were filed, on December 12 the District Court issued a temporary restraining order to preserve the status quo and to protect its own jurisdiction. See App. 40-47. Given that the next morning (December 13) was the pre-established deadline for voting, many, if not most, of the ballots had already been returned by the union’s voting members. Nonetheless, the court noted that federal-court jurisdiction was available under § 102 of Title I, 29 U. S. C. § 412, for claims alleging discriminatory application of union rules. Moreover, the court’s order specifically required that the ballots be sealed and delivered to the court, thereby preventing the petitioners from counting the ballots until a final determination could be made on the motion for a preliminary injunction.

Several days of hearings on the preliminary injunction, and several months of negotiations concerning an appropriate court order to accompany that injunction, followed. Finally, on July 13, 1981, the District Court issued a preliminary injunction accompanied by a memorandum opinion. 521 F. Supp. 614 (1981). The court first addressed more fully the petitioners’ argument that, because the challenged conduct concerned the procedures for conducting union elections, the respondents’ exclusive remedy was to file a complaint with the Secretary of Labor under Title IV. The court rejected this argument, noting that, “at least with respect to actions challenging pre-election conduct, Title I of the LMRDA establishes an alternative enforcement mechanism for remedying conduct interfering with a member’s right to engage in the activities associated with union democracy.” Id., at 621 (footnote omitted).

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Bluebook (online)
467 U.S. 526, 104 S. Ct. 2557, 81 L. Ed. 2d 457, 1984 U.S. LEXIS 107, Counsel Stack Legal Research, https://law.counselstack.com/opinion/local-no-82-furniture-piano-moving-furniture-store-drivers-helpers-scotus-1984.