PAULA TAYLOR & Another v. BOSTON TEACHERS UNION, LOCAL 66, AFT MASSACHUSETTS, AFL-CIO.

CourtMassachusetts Appeals Court
DecidedJuly 30, 2024
Docket23-P-0419
StatusUnpublished

This text of PAULA TAYLOR & Another v. BOSTON TEACHERS UNION, LOCAL 66, AFT MASSACHUSETTS, AFL-CIO. (PAULA TAYLOR & Another v. BOSTON TEACHERS UNION, LOCAL 66, AFT MASSACHUSETTS, AFL-CIO.) 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
PAULA TAYLOR & Another v. BOSTON TEACHERS UNION, LOCAL 66, AFT MASSACHUSETTS, AFL-CIO., (Mass. Ct. App. 2024).

Opinion

NOTICE: Summary decisions issued by the Appeals Court pursuant to M.A.C. Rule 23.0, as appearing in 97 Mass. App. Ct. 1017 (2020) (formerly known as rule 1:28, as amended by 73 Mass. App. Ct. 1001 [2009]), are primarily directed to the parties and, therefore, may not fully address the facts of the case or the panel's decisional rationale. Moreover, such decisions are not circulated to the entire court and, therefore, represent only the views of the panel that decided the case. A summary decision pursuant to rule 23.0 or rule 1:28 issued after February 25, 2008, may be cited for its persuasive value but, because of the limitations noted above, not as binding precedent. See Chace v. Curran, 71 Mass. App. Ct. 258, 260 n.4 (2008).

COMMONWEALTH OF MASSACHUSETTS

APPEALS COURT

23-P-419

PAULA TAYLOR & another1

vs.

BOSTON TEACHERS UNION, LOCAL 66, AFT MASSACHUSETTS, AFL-CIO.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

The plaintiffs, Paula Taylor and John Daley, both members

of the Boston Teachers Union (BTU or defendant), appeal from a

judgment of the Superior Court dismissing their complaint

seeking declaratory relief pursuant to G. L. c. 231A, § 1. We

affirm.

Background. Taking the plaintiffs' well-pleaded

allegations as true, at a February 9, 2022 monthly union

membership meeting a draft memorandum of agreement (MOA) between

the Boston Public Schools and the BTU was presented to the

attending membership for a vote. "The [February 2022] MOA,

among other things, divided the workforce into 'verified' and

'non-verified' employees depending upon which medical treatments

1 John Daley. they preferred," and further provided for the imposition of

unpaid leave for "'non-verified' employees based upon [certain]

contingencies." The February 2022 MOA also purported to reduce

compensation for employees "who used sick days as compensation

during unpaid leave." The union membership voted in favor of

the February 2022 MOA.

On February 14, 2022, the plaintiffs filed a complaint

against the defendant alleging that the defendant conducted a

vote on the February 2022 MOA in violation of notice and voting

requirements of the union bylaws. Article X of the BTU's bylaws

provides that "[a]ny motion which alters or amends our

collective bargaining agreement shall require the same notice to

the membership as a constitutional amendment." Article X

further provides that proposed amendments to the bylaws "[s]hall

be announced to the membership in writing at least fifteen (15)

days in advance of the next meeting of the membership," and that

proposed amendments "shall become part of the Bylaws of the

[union] by two-thirds (2/3) vote of those present and voting in

favor."

The plaintiffs argue that the above-referenced provisions

of the February 2022 MOA "substantially altered the rights and

obligations of the members under the union's Collective

Bargaining Agreement [CBA]," thus triggering the Article X bylaw

provisions requiring fifteen days advance written notice and a

2 two-thirds supermajority vote. The plaintiffs claim that by

failing to give that required notice and failing to require a

supermajority vote, the defendant breached the bylaws and

proceeded on an unlawful basis without the authority of union

membership. Accordingly, the plaintiffs seek a declaration that

the defendant's actions violated the bylaws and are unlawful.

The defendant moved to dismiss the complaint on the basis

that, inter alia, paragraph 19 of the February 2022 MOA requires

the "approval of the Boston School Committee" (BSC) to become

effective, and the BSC has never voted on or approved the

February 2022 MOA. Consequently, the defendant argued, the

request for declaratory relief was not ripe for adjudication as

there was no actual controversy within the meaning of G. L.

c. 231A. The plaintiffs filed an opposition to the motion to

dismiss and subsequently filed a motion to supplement the

pleadings pursuant to Mass. R. Civ. P. 15 (d), 365 Mass. 761

(1974). The motion to supplement sought, in essence, to amend

the complaint to include allegations regarding a subsequent

September 6, 2022 MOA that contained a requirement for union

members to "verify their vaccination status" and in some

circumstances submit to an unspecified "COVID-19 screening

test." The plaintiffs maintained that certain provisions of the

September 2022 MOA likewise altered or amended rights and

obligations in the CBA and were thus subject to the notice and

3 supermajority provisions of Article X of the bylaws and likewise

were unlawful. The defendant filed an opposition to the motion

to supplement arguing that the September 2022 MOA did not alter

the terms and conditions of employment for union members. On

January 31, 2023, a Superior Court judge allowed the defendant's

motion to dismiss and denied the plaintiffs' motion to

supplement. This appeal ensued.

Discussion. We review the allowance of a motion to dismiss

de novo, accepting the allegations in the complaint as true and

drawing all reasonable inferences in the plaintiff's favor. See

Curtis v. Herb Chambers I-95, Inc., 458 Mass. 674, 676 (2011).

"[W]e look beyond the conclusory allegations in the complaint

and focus on whether the factual allegations plausibly suggest

an entitlement to relief." Id., citing Iannacchino v. Ford

Motor Co., 451 Mass. 623, 635-636 (2008).

With respect to declaratory judgment actions, G. L. c. 231A

"expressly requires that the pleadings set forth specifically

some actual controversy." Penal Insts. Comm'r for Suffolk Co.

v. Commissioner of Correction, 382 Mass. 527, 530-531 (1981),

citing G. L. c. 231A, §§ 1, 9. "Such proceedings are concerned

with the resolution of real, not hypothetical, controversies;

the declaration issued is intended to have an immediate impact

on the rights of the parties." Id. at 531, quoting

Massachusetts Ass'n of Independent Ins. Agents & Brokers, Inc.

4 v. Commissioner of Ins., 373 Mass. 290, 292 (1977). "Conclusory

allegations as to official duties or potential future conflicts

will not do." Penal Insts. Comm'r for Suffolk Co., supra. With

these principles in mind, we address the plaintiffs' claims on

appeal.

As to the February 2022 MOA, there is no dispute that it

was never approved by the BSC and never went into effect. As a

result, these circumstances present a hypothetical controversy

where the declaration sought by the plaintiffs -- i.e., that the

MOA not in effect is nonetheless unlawful -- would not have an

"immediate impact" on the rights of the parties. Massachusetts

Ass'n of Independent Ins. Agents & Brokers, 373 Mass. at 292.

Plaintiffs' argument would also fail because "[a] party has

standing pursuant to G. L. c. 231A where the defendant has

violated some duty owed to the plaintiff[s] . . . and where the

plaintiffs can allege an injury within the area of concern of

the statute or regulatory scheme" (quotations omitted). Service

Employees Int'l Union, Local 509 v. Department of Mental Health,

469 Mass. 323, 328 (2014). Here, for the reasons stated above,

the plaintiffs do not allege a cognizable injury within the

meaning of c. 231A.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Service Employees International Union, Local 509 v. Department of Mental Health
14 N.E.3d 216 (Massachusetts Supreme Judicial Court, 2014)
L.L., a juvenile v. Commonwealth
20 N.E.3d 930 (Massachusetts Supreme Judicial Court, 2014)
Chang v. Winklevoss
123 N.E.3d 204 (Massachusetts Appeals Court, 2019)
McCaffrey v. School Committee
226 N.E.2d 232 (Massachusetts Supreme Judicial Court, 1967)
Penal Institutions Commissioner v. Commissioner of Correction
416 N.E.2d 958 (Massachusetts Supreme Judicial Court, 1981)
Enos v. Secretary of Environmental Affairs
432 Mass. 132 (Massachusetts Supreme Judicial Court, 2000)
Iannacchino v. Ford Motor Co.
451 Mass. 623 (Massachusetts Supreme Judicial Court, 2008)
Curtis v. Herb Chambers I-95, Inc.
458 Mass. 674 (Massachusetts Supreme Judicial Court, 2011)
Entergy Nuclear Generation Co. v. Department of Environmental Protection
944 N.E.2d 1027 (Massachusetts Supreme Judicial Court, 2011)
Chace v. Curran
881 N.E.2d 792 (Massachusetts Appeals Court, 2008)

Cite This Page — Counsel Stack

Bluebook (online)
PAULA TAYLOR & Another v. BOSTON TEACHERS UNION, LOCAL 66, AFT MASSACHUSETTS, AFL-CIO., Counsel Stack Legal Research, https://law.counselstack.com/opinion/paula-taylor-another-v-boston-teachers-union-local-66-aft-massappct-2024.