United Steelworkers of America v. Sadlowski

457 U.S. 102, 102 S. Ct. 2339, 72 L. Ed. 2d 707, 1982 U.S. LEXIS 118
CourtSupreme Court of the United States
DecidedOctober 4, 1982
Docket81-395
StatusPublished
Cited by208 cases

This text of 457 U.S. 102 (United Steelworkers of America v. Sadlowski) 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
United Steelworkers of America v. Sadlowski, 457 U.S. 102, 102 S. Ct. 2339, 72 L. Ed. 2d 707, 1982 U.S. LEXIS 118 (1982).

Opinions

Justice Marshall

delivered the opinion of the Court.

In this case, we confront the question whether § 101(a)(2) of the Labor-Management Reporting and Disclosure Act of 1959 (LMRDA), 73 Stat. 522, 29 U. S. C. § 411(a)(2), precludes the membership of a union from adopting a rule that prohibits candidates for union office from accepting campaign contributions from nonmembers. The United States Court of Appeals for the District of Columbia Circuit held that such a rule violated § 101(a)(2). 207 U. S. App. D. C. 189, 645 F. 2d 1114 (1981). We granted certiorari, 454 U. S. 962 (1981), and now reverse.

I

A

Petitioner United Steelworkers of America (USWA), a labor organization with 1,300,000 members, conducts elections for union president and other top union officers every four years. The elections for these officers are decided by referendum vote of the membership. In the 1977 election, which was hotly contested, two candidates ran for president: respondent Edward Sadlowski, Jr., the Director of USWA’s largest district, and Lloyd McBride, another District Director.1 Both Sadlowski and McBride headed a slate of candidates for the other top union positions.

McBride was endorsed by the incumbent union leadership, and received substantial financial support from union officers and staff. Sadlowski, on the other hand, received much of his financial support from sources outside the union. During the campaign, the question whether candidates should accept [105]*105contributions from persons who were not members of the union was vigorously debated. The McBride slate contended that outsider participation in USWA elections was dangerous for the union. App. 27, n. 2, 298. See also id., at 129, 398; see generally id., at 40-48. McBride ultimately defeated Sadlowski by a fairly wide margin — 57% to 43%. The other candidates on the McBride slate won by similar margins.

After the elections, union members continued to debate the question whether outsider participation in union campaigns was desirable. This debate was finally resolved in 1978, when USWA held its biennial Convention. The Convention, which consists of approximately 5,000 delegates elected by members of USWA’s local unions, is USWA’s highest governing body. At the 1978 Convention, several local unions submitted resolutions recommending amendment of the USWA Constitution to include an “outsider rule” prohibiting campaign contributions by nonmembers. The union’s International Executive Board also recommended a ban on nonmember contributions. Acting on the basis of these recommendations, the Convention’s Constitution Committee proposed to the Convention that it adopt an outsider rule. After a debate on the floor of the Convention, the delegates, by a margin of roughly 10 to 1, voted to include such a rule in the Constitution. Id., at 35-36, 81-105.

The outsider rule, Article V, §27, of the USWA Constitution (1978), provides in pertinent part: [106]*106Section 27 confers authority upon the International Executive Board to adopt regulations necessary to implement the provision. It also creates a Campaign Contribution Administrative Committee, consisting of three “distinguished, impartial” nonmembers to administer and enforce the provision. The Committee may order a candidate to cease and desist from conduct that breaches §27, and may declare a candidate disqualified. Its decisions are final and binding.

[105]*105“Sec. 27. No candidate (including a prospective candidate) for any position set forth in Article IV, Section 1, and supporter of a candidate may solicit or accept financial support, or any other direct or indirect support of any kind (except an individual’s own volunteered personal time) from any non-member.”2

[106]*106B

In October 1979, Sadlowski and several other individuals3 filed suit against USWA in the United States District Court for the District of Columbia. They claimed, inter alia, that the outsider rule violated the “right to sue” provision of Title I of the LMRDA, § 101(a)(4), 73 Stat. 522, 29 U. S. C. § 411(a)(4), because it would prohibit a candidate from accepting nonmember contributions to finance campaign-related litigation. Both sides moved for summary judgment. The District Court found that the rule violated § 101(a)(4). 507 F. Supp. 623, 625 (1981). The District Court further decided to invalidate the rule in toto, because the portion of the rule that “limits meaningful access to the courts . . . cannot be separated or isolated from the rule in its entirety.” Ibid.

The United States Court of Appeals for the District of Columbia Circuit affirmed. 207 U. S. App. D. C. 189, 645 [107]*107F. 2d 1114 (1981). The court agreed that Article V, § 27, violated the right-to-sue provision. However, it chose not to decide whether this violation alone justified an injunction restraining enforcement of the entire rule. It accepted respondents’ argument, first raised on appeal, that the outsider rule also violated the § 101(a)(2) “freedom of speech and assembly” provision, and that this violation justified the injunction. The Court of Appeals reasoned that the statutory goal of union democracy could be achieved only if “effective challenges can be made to the often-entrenched union leadership.” 207 U. S. App. D. C., at 197, 645 F. 2d, at 1122. But effective challenges are possible only if insurgent candidates can solicit contributions from outsiders. “Even without contribution limitations, challengers to the union leadership face substantial barriers, especially the electoral power of the union staff.” Id., at 196, 645 F. 2d, at 1121. The court rejected the union’s argument that even if the rule interfered with rights protected by the statute, it was protected by the proviso to § 101(a)(2), which gives a union authority to adopt “reasonable” rules regarding the responsibilities of its members. Id., at 198, 645 F. 2d, at 1123.

To buttress its analysis, the Court of Appeals relied heavily on its understanding of First Amendment jurisprudence. It stated that § 101(a)(2) places “essentially the same limits on labor unions with respect to outside campaign contributions that the First Amendment would if it applied to labor unions.” Id., at 195, 645 F. 2d, at 1120. Citing Buckley v. Valeo, 424 U. S. 1, 19 (1976) (per curiam), the Court of Appeals suggested that contribution rules that prevent candidates for political office from amassing the resources necessary for effective advocacy are unconstitutional. By analogy, since the outsider rule would interfere with effective advocacy in union campaigns, it must violate § 101(a)(2). 207 U. S. App. D. C., at 197, 645 F. 2d, at 1122.

[108]*108HH HH

Section 101(a)(2) is contained in Title I of the LMRDA, the “Bill of Rights of Members of Labor Organizations.” See 29 U. S. C. §§411-415. It provides:

“Freedom of Speech and Assembly.

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Bluebook (online)
457 U.S. 102, 102 S. Ct. 2339, 72 L. Ed. 2d 707, 1982 U.S. LEXIS 118, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-steelworkers-of-america-v-sadlowski-scotus-1982.