Karahalios v. Nat'l Fed'n of Fed. Employees
Annotate this Case
489 U.S. 527 (1989)
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U.S. Supreme Court
Karahalios v. Nat'l Fed'n of Fed. Employees, 489 U.S. 527 (1989)
Karahalios v. National Federation of Federal Employees,
Argued January 17, 1989
Decided March 6, 1989
489 U.S. 527
Petitioner -- a language instructor for the Defense Language Institute, a federal agency -- was not a union member but was within a bargaining unit for which respondent union was the exclusive bargaining agent. He was promoted to a reopened "course developer" position, which had previously been occupied by one Kuntelos, who was demoted when the Institute first abolished the position. After respondent agreed to arbitrate on behalf of Kuntelos (who was a member of its board) and successfully argued that the position should be declared vacant for refilling, the Institute reassigned the job to Kuntelos, demoted petitioner, and denied his direct protest. Respondent refused to prosecute petitioner's grievance because of a perceived conflict of interest with its previous Kuntelos advocacy. Petitioner then filed unfair labor practice charges with the Federal Labor Relations Authority (FLRA), alleging, inter alia, that respondent had breached its duty of fair representation. The FLRA's General Counsel upheld this charge, and ordered that a complaint be issued against respondent, which entered into a settlement whereby it posted notice guaranteeing representation to all employees seeking a single position. When the General Counsel rejected petitioner's contention on appeal that the settlement provided him no relief, he filed a damages suit in the District Court, which held that his charge against respondent was judicially cognizable, since the grant of exclusive union representation contained in the Civil Service Reform Act of 1978 (CSRA or Act) impliedly gives federal employees a private right of action to safeguard their right to fair representation. However, the Court of Appeals reversed the judgment for petitioner, stating that the CSRA's statutory scheme, which creates both an express duty of fair representation and a remedy in the FLRA for infringement of this duty, precludes implication of a parallel right to sue in federal court.
Held: Title VII of the CSRA does not confer on federal employees a private cause of action against a breach by a union representing such employees of its statutory duty of fair representation. Pp. 489 U. S. 531-537.
(a) Title VII's express language does not create a private cause of action, and there is nothing in the Act's language, structure, or legislative history from which a congressional intent to provide such a remedy
can be implied. In fact, Title VII's provisions demonstrate that Congress vested exclusive enforcement authority over the duty of fair representation in the FLRA and its General Counsel, since the Title renders a breach of that duty an unfair labor practice, which is adjudicated by the FLRA upon the General Counsel's complaint, and since the Title provides recourse to the courts in only three instances, none of which directly relate to the enforcement of the duty of fair representation. To hold that the district courts must entertain such cases in the first instance would seriously weaken the congressional scheme. Pp. 489 U. S. 532-534.
(b) A congressional intent to provide a private CSRA cause of action cannot be implied from that Act's similarities to the National Labor Relations Act (NLRA) and the Railway Labor Act, under which this Court has recognized implicit judicial causes of action to enforce the fair representation duty in the private sector. Unlike the CSRA, neither of those statutes expressly recognizes that duty or provides any administrative remedy for its enforcement. Furthermore, the implication in Vaca v. Sipes, 386 U. S. 171, of a private NLRA cause of action was intended to preserve courts' preexisting jurisdiction to enforce the fair representation duty after the National Labor Relations Board tardily assumed jurisdiction, whereas, under the pre-CSRA regulatory scheme, there was no equivalent judicial role. Moreover, Vaca and earlier cases stressed that it was critical that unions represent all employees in good faith, since the pertinent statutes deprived bargaining unit employees of their individual rights to bargain by providing for exclusive bargaining agents. In contrast, federal employment does not rest on contract in the private sector sense; the deprivation a federal employee suffers from the election of a bargaining agent -- if there is such a deprivation -- is not clearly comparable to the private sector predicament; and the collective bargaining mechanisms created by Title VII do not deprive employees of remedies otherwise provided by statute or regulation. Vaca also rested in part on the fact that private collective bargaining contracts were enforceable in the courts under § 301 of the NLRA, whereas no provision equivalent to § 301 exists in the CSRA. Pp. 489 U. S. 534-536.
821 F.2d 1389, affirmed.
WHITE, J., delivered the opinion for a unanimous Court.