Reed v. United Steel Workers District 7

CourtDistrict Court, S.D. Illinois
DecidedApril 21, 2025
Docket3:24-cv-00192
StatusUnknown

This text of Reed v. United Steel Workers District 7 (Reed v. United Steel Workers District 7) is published on Counsel Stack Legal Research, covering District Court, S.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Reed v. United Steel Workers District 7, (S.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

CARLOS REED,

Plaintiff,

v. Case No. 3:24-cv-192-NJR

UNITED STEEL, PAPER AND FORESTRY, RUBBER, MANUFACTURING, ENERGY, ALLIED INDUSTRIAL AND SERVICE WORKERS INTERNATIONAL UNION (USW) AND UNITED STEELWORKERS, DISTRICT 7,

Defendants.

MEMORANDUM AND ORDER

ROSENSTENGEL, Chief Judge:

Pending before the Court is a Motion to Dismiss Pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure filed by Defendants United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International Union (USW) and United Steelworkers, District 7 (collectively, “the Union”). (Doc. 28). Plaintiff Carlos Reed (“Reed”) filed a response in opposition. (Doc. 30). For the reasons set forth below, the Union’s motion to dismiss is granted. BACKGROUND The Court accepts as true the following facts, which are taken from the Amended Complaint. (Doc. 27). Reed, who is Black or African American, worked at Solvay Fluorides, LLC’s Alorton, Illinois plant from June 17, 1991, until his termination on March 28, 2022. (Id. at ¶¶ 12-13). Reed became a master mechanic in 2014. (Id. at ¶ 14). He was fired for allegedly removing scrap material from Solvay and for unauthorized entrance

onto Solvay’s premises. (Id. at ¶ 25). While employed with Solvay, Reed was a member of the collective bargaining unit there. (Id. at ¶ 15). The Union entered into a collective bargaining agreement with Solvay effective August 1, 2019, and was the sole representative of the members of the collective bargaining unit. (Id. at ¶¶ 16-17). The collective bargaining agreement set forth a four- step grievance process with the last step being a demand for arbitration that could only

be carried out by the Union. (Id. at ¶¶ 18-19, 21-22). Any member of the collective bargaining unit is permitted to file a grievance under the collective bargaining agreement. (Id. at ¶ 20). Reed filed several grievances with the Union throughout his employment at Solvay, including grievances concerning the terms and conditions of his employment and

minor disciplinary action taken against him. (Id. at ¶ 23). The Union did not take any of these grievances to arbitration. (Id. at ¶ 24). Reed filed another grievance following his termination for the alleged theft of scrap materials and improper entry onto Solvay’s property. (Id. at ¶ 25). The grievance went through the first three steps of the process, and the Union demanded arbitration

pursuant to step four of the grievance process. (Id. at ¶¶ 26-27). The grievance, however, ultimately did not proceed to arbitration. (Id. at ¶ 28). Instead, the Union settled the grievance and withdrew it. (Id. at ¶ 29). The settlement agreement provided that if Reed withdrew his grievance, Solvay would not prosecute Reed for his actions and would provide Reed with a neutral employment recommendation. (Id. at ¶ 30). Reed was not aware of this settlement, nor did he agree to settle or withdraw his grievance. (Id. at ¶ 31).

In fact, Reed asserts that he would not have agreed to the withdrawal of his grievance because he believed his termination was wrongful and the result of racial discrimination. (Id. at ¶ 32). Reed also alleges that the Union did not conduct any investigation into whether the removal of scrap by employees was condoned by management at Solvay, whether similarly situated employees were treated differently than Reed, or whether his termination was the result of racial discrimination. (Id. at ¶¶ 33-35).

On December 13, 2022, Reed filed a charge against the Union with the Illinois Department of Human Rights (“IDHR”). (Id. at ¶ 7). Reed alleged the Union violated its duty of fair representation related to the processing of his grievance and that the violation was the result of discrimination on the basis of Reed’s race. (Id.). On September 19, 2023, the IDHR found that there was a lack of substantial evidence supporting Reed’s claim of

racial discrimination. (Id. at ¶ 8). As permitted under the Illinois Human Rights Act (“IHRA”), Reed then filed a civil action in the Circuit Court of St. Clair County, Illinois, within 90 days of the IDHR’s finding of no substantial evidence of discrimination. (Id. at ¶¶ 9-10). The Union removed the case to this Court on January 29, 2024. (Doc. 11). Reed then

amended his complaint to assert a claim of discrimination in violation of 42 U.S.C. §1981 (Count 1) and discrimination in violation of the IHRA (Count 2). Upon the Union’s filing of the instant Motion to Dismiss (Doc. 28), Reed agreed to voluntarily dismiss his IHRA claim in Count II. (Doc. 30 at p. 3). Thus, Count II shall be dismissed, and the Court will proceed to analyze only whether Reed has stated a § 1981 claim for discrimination. LEGAL STANDARD

A defendant’s motion to dismiss may be granted in instances where the plaintiff’s complaint fails to “state a claim upon which relief can be granted.” FED. R. CIV. P. 12(b)(6). For a plaintiff to survive a motion to dismiss, the complaint must contain sufficient factual allegations “to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). To be plausible, an allegation must allow “the court to draw the

reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). The factual allegations stated in the amended complaint will be taken as true and interpreted in “the light most favorable” to the plaintiff. Burke v. 401 N. Wabash Venture, LLC, 714 F.3d 501, 504 (7th Cir. 2013). However, “threadbare recitals of a cause of action’s

elements, supported by mere conclusory statements” are not entitled to the presumption of truth. Ashcroft, 556 U.S. at 663. This standard does not require “detailed factual allegations.” Bell Atl. Corp., 550 U.S. at 555. Rather, it simply requires that that the plaintiff gives “enough details about the subject-matter of the case to present a story that holds together.” Swanson v. Citibank, N.A., 614 F.3d 400, 404 (7th Cir. 2010).

DISCUSSION Section 1981 prohibits racial discrimination in the “making, performance, modification, and termination of contracts, and the enjoyment of all benefits, privileges, terms, and conditions of the contractual relationship.” 42 U.S.C. § 1981(b). To establish a race discrimination claim against a union under § 1981, a plaintiff must demonstrate that the union refused to process his grievances because of his race or his earlier complaints

about race. Webb v. AFSCME Council 31, No. 19-CV-4192, 2020 WL 919260, at *2 (N.D. Ill. Feb. 26, 2020) (citing Green v. AFT/IFT Local 604, 740 F.3d 1104, 1107 (7th Cir. 2014)); see also Chapman v. AFSCME Council 31, Loc. 3477, No. 17 C 8125, 2019 WL 214478, at *6 (N.D. Ill. Jan. 16, 2019) (§ 1981 “prohibit[s] unions from discriminating on the basis of race in the way they represent their members”). In other words, a racial discrimination claim under § 1981 requires a plaintiff to show that the union would have processed his

grievances had he been white. Id.

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Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Swanson v. Citibank, N.A.
614 F.3d 400 (Seventh Circuit, 2010)
Michael Burke v. 401 N. Wabash Venture, L.L.C.
714 F.3d 501 (Seventh Circuit, 2013)
Green v. American Federation of Teachers
740 F.3d 1104 (Seventh Circuit, 2014)

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Reed v. United Steel Workers District 7, Counsel Stack Legal Research, https://law.counselstack.com/opinion/reed-v-united-steel-workers-district-7-ilsd-2025.