Steelworkers v. Usery - 429 U.S. 305 (1977)
U.S. Supreme Court
Steelworkers v. Usery, 429 U.S. 305 (1977)
Local 3489, United Steelworkers of America, AFL-CIO v. Usery
Argued November 30, 1976
Decided January 12, 1977
429 U.S. 305
The provision of petitioner labor unions' constitution limiting eligibility for local union office to members who have attended at least one-half of the local's regular meetings for three years previous to the election of officers, held to violate § 401(e) of the Labor-Management Reporting and Disclosure Act of 1959, which provides that every union member in good standing shall be eligible to be a candidate and to hold office, subject to "reasonable qualifications." Pp. 429 U. S. 308-314.
(a) Where such meeting attendance requirement resulted in the exclusion of 96.5% of petitioner local's members from candidacy for office, the requirement cannot be considered a "reasonable qualification" consistent with Title IV's goal of free and democratic union elections, since a requirement having that result restricts the free choice of the membership in selecting its leaders. P. 429 U. S. 310.
(b) The requirement has a restrictive effect on union democracy even when considered as simply mandating a procedure to be followed by any member who wishes to be a candidate, rather than as excluding a category of members from eligibility for office, since it is probable that to require a member to decide upon a potential candidacy at least 18 months in advance of an election when no issues exist to prompt that decision may discourage candidacies, and, to that extent, impair the general membership's freedom to oust incumbents in favor of new leadership. Pp. 429 U. S. 310-311.
(c) Procedures that unduly restrict free choice among candidates are forbidden without regard to their success or failure in maintaining corrupt leadership, and hence it is immaterial whether or not it was shown that incumbent leaders of petitioner local became "entrenched" in their offices as a consequence of the operation of the meeting attendance requirement. Pp. 429 U. S. 311-312.
(d) The challenged requirement cannot be justified as encouraging attendance at union meetings, since it plainly has not served that goal. Nor can it be justified as assuring the election of knowledgeable and dedicated leaders, since Congress has determined that the best means
to this end is open democratic elections, unfettered by unreasonable candidacy restrictions. P. 429 U. S. 312.
(e) In using the term "reasonable qualifications," Congress clearly contemplated a flexible standard, which takes into account all the circumstances of a particular case, for determining the reasonableness of a meeting attendance requirement. P. 429 U. S. 313.
520 F.2d 516, affirmed.
BRENNAN, J., delivered the opinion of the Court, in which BURGER, C.J., and WHITE, MARSHALL, BLACKMUN, and STEVENS, JJ., joined. POWELL, J., filed a dissenting opinion, in which STEWART and REHNQUIST, JJ., joined, post, p. 429 U. S. 314.