IBEW v. Foust
Annotate this Case
442 U.S. 42 (1979)
U.S. Supreme Court
IBEW v. Foust, 442 U.S. 42 (1979)
International Brotherhood of Electrical Workers v. Foust
Argued February 26, 1979
Decided May 29, 1979
442 U.S. 42
Respondent was discharged by his employer, the Union Pacific Railroad Co., for failing properly to request an extension of his medical leave of absence. Petitioner union filed a grievance on respondent's behalf two days after the time for submission had expired. The National Railroad Adjustment Board denied respondent's claim on the ground that the union had not complied with the filing deadline. Respondent then brought an unfair representation suit against the union. A jury found for respondent, awarding him actual and punitive damages. The Court of Appeals affirmed in most respects, but remanded the case for consideration of whether the punitive damages award was excessive.
Held: The Railway Labor Act does not permit an employee to recover punitive damages for a union's breach of its duty of fair representation in processing an employee's grievance against his employer for wrongful discharge. Pp. 442 U. S. 46-52.
(a) Since Congress has not specified what remedies are available in unfair representation actions, this Court's function is to implement a remedial scheme that will best effectuate the purposes of the Railway Labor Act, recognizing that the overarching legislative goal is to facilitate collective bargaining and to achieve industrial peace. Pp. 442 U. S. 47-48.
(b) The fundamental purpose of unfair representation suits is to compensate for injuries caused by violations of employees' rights. To permit punitive damages, which, by definition, provide monetary relief in excess of actual loss, could impair the financial stability of unions and unsettle the careful balance of individual and collective interests which this Court has struck in the unfair representation area. Additionally, the prospect of punitive damages could curtail the broad discretion afforded unions in handling grievances and thereby inhibit the proper functioning of the collective bargaining system. Inflicting such risks on employees, whose welfare depends on the strength of their unions, is too great a price for whatever deterrent effect punitive damages may have. Pp. 442 U. S. 48-52.
572 F.2d 710, reversed in part.
MARSHALL, J., delivered the opinion of the Court, in which BRENNAN, STEWART, WHITE, and POWELL, JJ., joined. BLACKMUN, J., filed an opinion concurring in the result, in which BURGER, C.J., and REHNQUIST and STEVENS, JJ., joined, post, p. 442 U. S. 52.