Steelworkers v. Sadlowski
Annotate this Case
457 U.S. 102 (1982)
U.S. Supreme Court
Steelworkers v. Sadlowski, 457 U.S. 102 (1982)
United Steelworkers of America, AFL-CIO-CLC v. Sadlowski
Argued March 31, 1982
Decided June 14, 1982
457 U.S. 102
Petitioner union amended its constitution to include an "outsider rule" which prohibits candidates for union office from accepting campaign contributions from nonmembers and creates a committee to enforce the rule, the committee's decisions being final and binding. Respondents, including a union member who had been an unsuccessful candidate for union office before adoption of the outsider rule and had received much of the financial support for his campaign from sources outside the union, filed suit against petitioner in Federal District Court, claiming that the rule prohibited nonmember contributions to finance campaign-related litigation, and thus violated § 101(a)(4) of the Labor-Management Reporting and Disclosure Act of 1959 (LMRDA), which provides that a union may not limit the rights of its members to institute an action in any court or administrative agency. The District Court found for respondents. The Court of Appeals affirmed, agreeing that the outsider rule violated § 101(a)(4). It also accepted respondents' argument, first raised on appeal, that the rule violated the "freedom of speech and assembly" provision of § 101(a)(2) of the LMRDA giving every union member the right to assemble freely with other members and to express at union meetings his views about candidates in union elections or any business properly before the meeting. The Court of Appeals rejected petitioner's argument that the outsider rule was protected by § 101(a)(2)'s proviso, which gives a union authority to adopt "reasonable" rules regarding its members' responsibilities.
1. Petitioner's outsider rule does not violate § 101(a)(2). Although it may interfere with rights Congress intended to protect, it is rationally related to a legitimate and protected purpose, and thus is sheltered by § 101(a)(2)'s proviso. Pp. 457 U. S. 108-119.
(a) In light of the legislative history, § 101(a)(2) cannot be read as incorporating the entire body of First Amendment law so as to require that the scope of protections afforded union members by the statute coincide with the protections afforded by the Constitution as to a political election candidate's freedom to receive campaign contributions. Union
rules are valid under the statute so long as they are reasonable; they need not pass the stringent tests applied in the First Amendment context. Pp. 457 U. S. 108-111.
(b) Congress adopted the freedom of speech and assembly provision of § 101(a)(2) in order to promote union democracy, particularly through fostering vigorous debate during election campaigns. Although petitioner's outsider rule does affect rights protected by the statute, and may limit somewhat the ability of insurgent union members to wage an effective campaign against incumbent officers, as a practical matter, the impact may not be substantial. The record shows that challengers have been able to defeat incumbents or administration-backed candidates despite the absence of financial support from nonmembers. Pp. 457 U. S. 111-115.
(c) Petitioner's purpose in adopting the outsider rule was to ensure that nonmembers would not unduly influence union affairs, and that the union leadership would remain responsive to the membership. The policies underlying the LMRDA show that this is a legitimate purpose that Congress meant to protect. Nor is the rule invalid on the asserted ground that it is not rationally related to that purpose because the union could have simply established contribution ceilings, or need not have limited contributions by relatives and friends, or could have simply required that candidates reveal the sources of their funds. Petitioner had a reasonable basis for its decision to impose a broad ban seeking to eradicate the threat of outside influence. Pp. 457 U. S. 115-119.
2. Petitioner's outsider rule does not violate § 101(a)(4)'s right-to-sue provision. The rule simply does not apply where a member uses funds from outsiders to finance litigation. Neither the rule's language nor the debates leading up to its passage indicate that petitioner intended the rule to apply in such context. Moreover, petitioner's rule-enforcement committee issued an opinion stating that the rule's limitations
"do not apply to the financing of lawsuits by nonmembers for the purpose of asserting the legal rights of candidates or other union members in connection with elections."
Pp. 457 U. S. 119-121.
207 U.S.App.D.C. 189, 645 F.2d 1114, reversed and remanded.
MARSHALL, J., delivered the opinion of the Court, in which POWELL, REHNQUIST, STEVENS, and O'CONNOR, JJ., joined. WHITE, J., filed a dissenting opinion, in which BURGER, C.J., and BRENNAN and BLACKMUN, JJ., joined, post, p. 457 U. S. 121.