Reed v. United Transp. Union
Annotate this Case
488 U.S. 319 (1989)
U.S. Supreme Court
Reed v. United Transp. Union, 488 U.S. 319 (1989)
Reed v. United Transportation Union
Argued November 2, 1988
Decided January 11, 1989
488 U.S. 319
Two years after the last of the complained-of events occurred, petitioner, an officer of a local chapter of respondent union, filed suit against the union and various of its officers, alleging that they had violated his right to free speech as to union matters under § 101(a)(2) of Title I of the Labor-Management Reporting and Disclosure Act of 1959 (LMRDA). There is no statute of limitations expressly applicable to § 101 actions. The District Court denied respondents' summary judgment motion, rejecting their argument that petitioner had filed his suit out of time and holding that the action was governed by North Carolina's 3-year statute of limitations for personal injury actions. The Court of Appeals reversed, construing DelCostello v. Teamsters, 462 U. S. 151, to require that petitioner's § 101(a)(2) claim be governed by the 6-month statute of limitations set forth in § 10(b) of the National Labor Relations Act (NLRA) for filing unfair labor practice charges with the National Labor Relations Board.
Held: Section 101(a)(2) claims are governed by state general or residual personal injury statutes of limitations. Pp. 488 U. S. 323-334.
(a) The well-established general rule requires that the most closely analogous state statute of limitations be borrowed for a federal cause of action not supplied by Congress with its own limitations period. However, a narrow exception to that rule requires the application of a statute of limitations from elsewhere in federal law when the analogous state statute will frustrate or significantly interfere with federal policies, the federal law clearly provides a closer analogy, and the federal policies at stake and the practicalities of litigation render the federal rule significantly more appropriate. Pp. 488 U. S. 323-325.
(b) The general borrowing rule requires that state general or residual personal injury statutes of limitations be applied to § 101(a)(2) suits. As a preliminary matter, it must be concluded that all such suits should be characterized in the same way, since the diversion of resources to collateral statute of limitations litigation would interfere with § 101(a)(2)'s core purpose of enhancing union democracy by protecting union members' rights to free speech and assembly from incursion by union leadership. Because § 101(a)(2) is modeled on the First Amendment, it is
readily analogized to state personal injury actions under the reasoning of Owens v. Okure, ante p. 488 U. S. 235, where it was held that suits under 42 U.S.C. § 1983, which also protects the exercise of First Amendment rights, are governed by state general or residual personal injury statutes of limitations. Moreover, since such state limitations periods are of sufficient length to accommodate the practical difficulties faced by § 101(a)(2) plaintiffs -- which include identifying the injury, deciding in the first place to sue and thereby to antagonize union leadership, and finding an attorney -- the practicalities of litigation do not require a search for a more analogous statute of limitations. Pp. 488 U. S. 325-327.
(c) The narrow exception to the general borrowing rule does not require the adoption of the § 10(b) limitations period for § 101(a)(2) claims. Respondents' argument to the contrary fails to take seriously the requirement that analogous state statutes of limitations are to be used unless they frustrate or significantly interfere with federal policies. The 6-month § 10(b) statute of limitations was crafted to accommodate federal interests in stable bargaining relationships between employers and unions and in private dispute resolution under collective bargaining agreements. Insofar as those interests are implicated by § 101(a)(2) claims, however, the relationship will generally be tangential or remote -- as in the present case, which involves an internal union dispute that can have only an indirect impact on economic relations between union and employer and on labor peace. More importantly, the core federal interest furthered by § 101(a)(2) -- the interest in union democracy promoted by union members' free speech and assembly rights -- simply had no part in the design of the § 10(b) statute of limitations for unfair labor practice charges. Indeed, Title I of the LMRDA was a response to a perception that the NLRA, including its unfair labor practices provisions, had failed to provide the necessary protections for free speech and other union members' rights. Hence, it is not the case here that the federal policies at stake in § 101(a)(2) actions make § 10(b) significantly more appropriate than the analogous state statutes of limitations that the established borrowing rule favors. DelCostello, supra, distinguished. Pp. 488 U. S. 327-334.
828 F.2d 1066, reversed and remanded.
BRENNAN, J., delivered the opinion of the Court, in which REHNQUIST, C.J., and MARSHALL, BLACKMUN, STEVENS, O'CONNOR, and KENNEDY, JJ., joined. SCALIA, J., filed an opinion concurring in the judgment, post, p. 488 U. S. 334. WHITE, J., filed a dissenting opinion, post, p. 488 U. S. 334.
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