Federation of Labor v. McAdory
Annotate this Case
325 U.S. 450 (1945)
U.S. Supreme Court
Federation of Labor v. McAdory, 325 U.S. 450 (1945)
Alabama State Federation of Labor v. McAdory
Argued April 3, 4, 1945
Decided June 11, 1945
325 U.S. 450
1. The Bradford Act (Alabama Laws of 1943, No. 298) is a comprehensive enactment regulating the activities and affairs of labor organizations having members who are employed in Alabama. Section 7 requires every labor organization "functioning" or "desiring to function" within the State to file a copy of the constitution and bylaws of its own and any parent organization, and to file annually a report giving prescribed information. The section makes it unlawful for any officer or agent to collect dues or other monies from any member while the labor organization is in default with respect to filing of the annual report. Section 15 makes it unlawful for any person or labor organization to collect, receive or demand any fee, assessment or money -- other than initiation fees or dues -- for a "work permit" or "as a condition for the privilege of work." Section 16 makes it unlawful for any "executive, administrative, professional, or supervisory employee to be a member in, or to be accepted for membership by, any labor organization" which admits to membership employees other than persons of these classes, but provides that the section is not to be construed "so as to interfere with or void any insurance contract now in existence and in force." Section 18 imposes civil liability and criminal penalties for violations of the Act. Petitioners (national and local labor organizations and an individual member) sought a declaratory judgment of unconstitutionality of §§ 7, 15 and 16.
(A) The contention that the Act denies equal protection of the laws, in violation of the Federal Constitution, because its provisions, or some of them, do not apply to business corporations or associations or to labor organizations which are subject to the Railway Labor Act, is without substance. P. 325 U. S. 471.
The State is not bound to regulate all types of organizations or none; it may begin with such as in its judgment most need regulation and may exclude those believed to be already appropriately regulated by either state or national legislation. P. 325 U. S. 472.
(B) Other issues as to the constitutional validity of the Act, as presented by the record before this Court, are inappropriate for decision in a declaratory judgment proceeding. P. 325 U. S. 472.
2. This Court can not say that §§ 7 and 18 could not be so construed and applied as not to deny the constitutional right of free speech and assembly; and, in the absence of any authoritative construction of the sections by the state courts, and upon a record which presents no concrete set of facts to which the Act is to be applied, the case in this aspect is plainly not one to be disposed of by the declaratory judgment procedure. P. 325 U. S. 460.
(a) The requirements for a justiciable case or controversy are no less strict in a declaratory judgment proceeding than in any other type of suit. P. 325 U. S. 461.
(b) It is the practice of this Court not to decide abstract, hypothetical or contingent questions; or to decide any constitutional question in advance of the necessity for its decision; or to formulate a rule of constitutional law broader than is required by the precise facts to which it is to be applied; or to decide any constitutional question except with reference to the particular facts to which it is to be applied. P. 325 U. S. 461.
(c) The declaratory judgment procedure may be resorted to only in the sound discretion of the Court and where the interests of justice will be advanced and an adequate and effective judgment may be rendered. P. 325 U. S. 462.
3. The record affords an inadequate factual basis for determining whether § 16 is applicable to any of petitioners' members, or if so whether as applied to them the Act would violate freedom of speech and assembly. P. 325 U. S. 462.
4. Nor may the validity of § 16 be here determined, in view of the state court's construction of the section as inapplicable wherever it would otherwise "interfere with or void any insurance contract now in existence and in force," and since it does not appear from the record whether and to what extent the section can be deemed applicable to petitioners' members because of existing insurance arrangements. P. 325 U. S. 463.
5. The constitutional validity of a statute may be attacked, in declaratory judgment proceedings as in any other, only by those to whom the statute applies and who are adversely affected by it. P. 325 U. S. 463.
6. Uncertainty as to the construction of §§ 7 and 16, and uncertainty as to the facts to which they are to be applied, preclude an adjudication upon this record that these sections conflict with the National Labor Relations Act. Pp. 325 U. S. 464, 325 U. S. 467.
(a) As none of the petitioners are shown to function as bargaining representatives for employees in industries subject to the National Labor Relations Act, or, if they do so, to function exclusively
as representatives for such employees, it can not be said that §§ 7 and 16 could in no circumstances be validly applied to any of them; and the Court is bound to assume the existence of any state of facts which would sustain the sections when they are assailed as unconstitutional. P. 325 U. S. 465.
(b) The Court cannot assume that the failure to file reports will result in the exclusion of petitioners, or any of them, from functioning in the State, or will visit any consequences upon them other than the penalty for failure to file; nor say, in the absence of any showing to the contrary, that the filing of information returns will impose such burdens on any of petitioners as to interfere with the performance of their functions under the National Labor Relations Act in cases where that Act is applicable. P. 325 U. S. 466.
(c) The validity of § 16 and whether it conflicts with the National Labor Relations Act can not be considered upon this record, in view of the ruling of the state court that the section is inapplicable wherever it would otherwise interfere with or render ineffective any existing contract of insurance, and in view of the failure of the petitioners to show to what extent §16 as so construed can be taken to be applicable to any of them because of existing insurance arrangements. P. 325 U. S. 466.
(d) A state statute may be voided as in conflict with federal legislation only if the conflict is clearly shown; and then only where the complainant shows that he is adversely affected by the alleged conflict. P. 325 U. S. 467.
7. Since the record presents no concrete case in which § 15 has been applied, the Court cannot say whether its application in circumstances not now presented would be so arbitrary and unreasonable as to deny due process. P. 325 U. S. 468.
8. The contention that the requirement of § 7 as to the filing of information statements and reports is so burdensome on labor organizations as to deny due process of law is not supported by the facts of record. P. 325 U. S. 469.
9. The objection that §§ 7 and 16 are unconstitutional as vague and uncertain can not appropriately be considered in a declaratory judgment proceeding in the federal courts in advance of their authoritative construction by a state court. P. 325 U. S. 470.
10. The extent to which the declaratory judgment procedure may be used in the federal courts to control state action lies in the sound discretion of the Court. It would be an abuse of discretion for this Court to make a pronouncement on the constitutionality of a state statute before it plainly appeared that the necessity for it had arisen, or when the Court is left in uncertainty, which it cannot
authoritatively resolve, a to the meaning of the statute when applied to any particular state of facts. P. 325 U. S. 471.
11. In the exercise of this Court's discretionary power to grant or withhold the declaratory judgment remedy, it is of controlling significance that it is in the public interest to avoid the needless determination of constitutional questions and the needless obstruction to the domestic policy of the States by forestalling state action in construing and applying its own statutes. P. 325 U. S. 471.
Certiorari, 323 U.S. 703, to review a judgment, 246 Ala. 1, 18 So.2d 810, upholding, in a declaratory judgment proceeding, the constitutionality of provisions of a state statute.
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