Furniture & Moving Drivers v. Crowley
Annotate this Case
467 U.S. 526 (1984)
U.S. Supreme Court
Furniture & Moving Drivers v. Crowley, 467 U.S. 526 (1984)
Local No. 82, Furniture & Piano Moving, Furniture Store
Drivers, Helpers, Warehousemen & Packers v. Crowley
Argued January 9, 1984
Decided June 12, 1984
467 U.S. 526
Title I of the Labor-Management Reporting and Disclosure Act of 1959 (LMRDA) provides a "Bill of Rights" for labor union members, including various protections for members involved in union elections. Section 102 provides that any person whose Title I rights have been violated may bring an action in federal district court "for such relief (including injunctions) as may be appropriate." Title IV of the Act provides an elaborate post-election procedure aimed at protecting union democracy through free and democratic elections. Section 402 provides that, if the Secretary of Labor (Secretary), upon complaint by a union member, finds probable cause to believe that a violation of Title IV election proceedings has occurred, he shall bring an action against the union in federal district court to set aside the election and to order a new election under the supervision of the Secretary. Section 403 provides that the remedy prescribed by Title IV for challenging an election already conducted shall be exclusive. Petitioner union, in preparation for an election scheduled for the last two months of 1980, held a meeting to nominate candidates for its executive board. Admission to the meeting was restricted to those union members who could produce a computerized receipt showing that their union dues had been paid. One of the respondents was among those members who were prohibited from entering the meeting for not possessing such a receipt. There was also a disagreement at the meeting as to the office for which another respondent had been nominated. These respondents and other respondent union members then filed a protest with the union, but it was denied. Election ballots were thereafter distributed with instructions that they be returned by mail so as to arrive in a designated post office box by 9 a.m. on December 13, 1980, at which time they were to be counted. On December 1, 1980, after the ballots had been distributed, respondents filed an action in Federal District Court, alleging that the union and petitioner union officers had violated Title I, and seeking a preliminary injunction. On December 12, the court issued a temporary restraining order halting the election. This was followed by several months of negotiations between the parties and hearings before the court. Ultimately, holding that Title I remedies
were not foreclosed when Title I violations occurred during the course of an election and rejecting petitioners' argument that respondents' exclusive remedy was to file a complaint with the Secretary under Title IV, the court issued a preliminary injunction and an order declaring the interrupted election invalid, setting forth detailed procedures to be followed during a new election, and appointing outside arbitrators to supervise implementation of the procedures. The Court of Appeals affirmed.
Held: The District Court overstepped the bounds of "appropriate" relief under Title I when it enjoined an ongoing union election and ordered that a new election be held pursuant to procedures imposed by the court. Pp. 467 U. S. 535-551.
(a) While § 102, standing by itself, suggests that individual union members may properly maintain a Title I suit whenever rights guaranteed by that Title have been violated, that section explicitly limits relief that may be ordered by a district court to that which is "appropriate" to any given situation. Moreover, while Title IV protects many of the same rights as does Title I, § 402 of Title IV sets up an exclusive method for protecting Title IV rights, and under this method, individuals are not permitted to block or delay union elections by filing suits for violation of Title IV. Pp. 467 U. S. 536-540.
(b) Whether suits alleging violations of Title I may properly be maintained during the course of a union election depends upon the appropriateness of the remedy required to eliminate the claimed violations. In the absence of legislative history suggesting that Congress intended to require or allow courts to preempt the Secretary's expertise and supervise their own elections, and given the clear congressional preference expressed in Title IV for supervision of new elections by the Secretary, the conclusion is compelled that Congress did not consider court supervision of union elections to be an "appropriate" remedy for a Title I suit filed during the course of an election. Thus, if the remedy sought is invalidation of an election already being conducted and court supervision of a new election, union members must utilize the remedies provided by Title IV. For less intrusive remedies sought during an election, however, a district court retains authority to order appropriate relief under Title I. Pp. 467 U. S. 540-550.
(c) The District Court's order here directly interfered with the Secretary's exclusive responsibilities for supervising new elections, and was inconsistent with the basic objectives of the LMRDA enforcement scheme. Pp. 467 U. S. 550-551.
679 F.2d 978, reversed and remanded.
BRENNAN, J., delivered the opinion of the Court, in which BURGER, C.J., and WHITE, MARSHALL, BLACKMUN, POWELL, REHNQUIST, and
O'CONNOR, JJ., joined. STEVENS, J., filed a dissenting opinion, post, p. 467 U. S. 552.
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