Sheet Metal Workers v. Lynn - 488 U.S. 347 (1989)
U.S. Supreme Court
Sheet Metal Workers v. Lynn, 488 U.S. 347 (1989)
Sheet Metal Workers International Assn. v. Lynn
Argued November 7, 1988
Decided January 18, 1989
488 U.S. 347
In an attempt to alleviate a financial crisis plaguing petitioner local union (Local), which is an affiliate of petitioner international union (International), the International's president appointed Richard Hawkins as trustee to supervise the Local's affairs, with authority under the International's constitution to suspend the Local's officers and business representatives. Five days after a special meeting at which the Local's membership defeated Hawkins' proposal to increase their dues, Hawkins notified respondent Lynn, an elected business representative of the Local, that he was being removed "indefinitely" from his position because of his outspoken opposition to the proposal at the meeting. After exhausting his intraunion remedies, Lynn brought suit in Federal District Court, claiming that his removal violated the free speech provision of Title I of the Labor-Management Reporting and Disclosure Act of 1959 (LMRDA or Act). The court granted summary judgment for petitioners under Finnegan v. Leu, 456 U. S. 431, which held that the discharge of a union's appointed business agents by the union president, following his election over the incumbent for whom the business agents had campaigned, did not violate Title I. However, the Court of Appeals reversed, holding that Finnegan did not control where the dismissed union official was elected, rather than appointed, and rejecting the contention that Lynn's removal was valid because it was carried out under Hawkins' authority as trustee.
Held: The removal of an elected business agent, in retaliation for statements he made at a union meeting in opposition to a dues increase sought by the union trustee, violates the LMRDA. Pp. 488 U. S. 352-359.
(a) Petitioners' argument is unpersuasive that Lynn's status as an elected, rather than an appointed, official is immaterial, and that the loss of his union employment cannot amount to a Title I violation because he remains a member of the Local and was not prevented from attending the special meeting, expressing his views on the dues proposal, or casting his vote. Even though Lynn was not actually prevented from exercising such Title I rights, his removal interfered with those rights by forcing him to chose between them and his job. Moreover, in contrast to the discharge of an appointed union official, the removal of an elected
official denies the members who voted for him the representative of their choice, and has a more pronounced chilling effect upon their exercise of their own Title I rights, thereby contravening the LMRDA's basic objective of ensuring that unions are democratically governed and responsive to the will of the membership, which must be free to discuss union policies and criticize the leadership without fear of reprisal. Finnegan, supra, distinguished.
(b) The cause of action of an elected union official removed for exercising his Title I rights is not affected by the fact that the removal is carried out during a trusteeship lawfully imposed under Title III of the Act. Nothing in the LMRDA's language or legislative history suggests that Title I rights are lost whenever a trusteeship is imposed. Given this congressional silence, a trustee's Title III authority ordinarily should be construed in a manner consistent with Title I's protections. As petitioners concede, the imposition of a trusteeship does not destroy the critical right to vote on dues increases which Title I guarantees to local union members. That right would not be meaningful if a trustee were able to control the members' debate over the issue. In the instant case, Lynn's statements concerning the proposed dues increase were entitled to protection, since nothing in the International's constitution suggests that the imposition of the trusteeship changed the nature of his office so that he was obligated to support Hawkins' positions. Pp. 488 U. S. 356-358.
804 F.2d 1472, affirmed.
MARSHALL, J., delivered the opinion of the Court, in which REHNQUIST, C.J., and BRENNAN, BLACKMUN, STEVENS, O'CONNOR, and SCALIA, JJ., joined. WHITE, J., filed an opinion concurring in the judgment, post, p. 488 U. S. 359. KENNEDY, J., took no part in the consideration or decision of the case.