Vaca v. Sipes
Annotate this Case
386 U.S. 171 (1967)
U.S. Supreme Court
Vaca v. Sipes, 386 U.S. 171 (1967)
Vaca v. Sipes
Argued November 17, 1966
Decided February 27, 1967
386 U.S. 171
Petitioners, union officials, were sued in a state court by a union member who alleged wrongful discharge by his employer in violation of the collective bargaining agreement and the union's arbitrary refusal to take his grievance to arbitration under the fifth and final step of the bargaining agreement's grievance procedures. The employee, whose duties required strenuous activity, was discharged on the ground of poor health. During the fourth grievance step, the union sent the employee to a physician for a complete examination. The report was unfavorable to the employee, and the union decided not to take the grievance to arbitration. After a jury verdict for the employee, the trial judge set aside the verdict on the ground that the NLRB had exclusive jurisdiction over the controversy. The Kansas City Court of Appeals affirmed, but the Missouri Supreme Court reversed and ordered the jury's verdict reinstated.
1. Since the union's duty, as exclusive agent, fairly to represent all members of a designated unit is based on federal statutes, federal law governs the employee's cause of action for breach of that duty. Pp. 386 U. S. 176-177.
2. Although the NLRB has recently held that a union's breach of its statutory duty of fair representation is an unfair labor practice under § 8(b) of the National Labor Relations Act, it does not follow that the broad preemption doctrine defined in San Diego Building Trades Council v. Garmon, 359 U. S. 236, holding that the NLRB has exclusive jurisdiction over activity arguably subject to § 8 of the Act, is applicable thereto. Pp. 386 U. S. 177-188.
(a) The preemption doctrine has not been rigidly applied where it could not be fairly inferred that Congress intended exclusive jurisdiction to lie with the NLRB. Pp. 386 U. S. 179-180.
(b) The preemption rule has not been applied where the activity regulated was merely a peripheral concern of the Labor Management Relations Act. P. 386 U. S. 180.
(c) The doctrine of fair representation, which protects individuals against arbitrary union conduct, might be jeopardized by the NLRB's failure to act in certain cases if the preemption
doctrine were applied to oust the courts of their traditional jurisdiction to curb arbitrary union conduct. Pp. 386 U. S. 181-183.
(d) As a practical matter, in an employee's suit against his employer for breach of contract under § 301 of the Labor Management Relations Act, the employee may well find it necessary to prove a breach of duty by his union, a facet of the case which does not destroy the court's jurisdiction, even if the employee joins the union as a defendant. That being so, the result should be no different if the employee sues the employer and the union in separate actions. Pp. 386 U. S. 183-187.
(e) Where a breach of duty by the union and a breach of contract by the employer are proven in a § 301 breach of duty action, the court must fashion an appropriate remedy against both defendants. Pp. 386 U. S. 187-188.
3. A union breaches its duty of fair representation when its conduct toward a member of the designated unit is arbitrary, discriminatory or in bad faith, but it does not breach that duty merely because it settles a grievance short of arbitration, and the Missouri Supreme Court erred in upholding the jury's verdict solely on the ground that the evidence supported the employee's claim of wrongful discharge. Pp. 386 U. S. 190-193.
4. As a matter of federal law, the evidence does not support a verdict that the union breached its duty, as the employee, who had no absolute right to have his grievance arbitrated, failed to prove arbitrary or bad faith conduct by the union in processing his grievance. Pp. 386 U. S. 193-195.
5. The claimed damages, which were primarily those suffered as a result of the employer's alleged breach of contract, should not have been all charged to the union, and, if liability were found, it should have been apportioned between the employer and the union according to the damages caused by the fault of each. Pp. 386 U. S. 195-198.
397 S.W.2d 658, reversed.
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