Teamsters Local No. 391 v. Terry

Brief Fact Summary. Teamsters Local No. 391 (Plaintiffs) requested a jury trial in an action claiming that the Union (Defendant) breached a collective bargaining agreement. The United States Court of Appeals for the Fourth Circuit affirmed the trial court holding that the Seventh Amendment entitled Plaintiffs to a jury trial. The Supreme Court of the United States granted certiorari.
Synopsis of Rule of Law. A party has the right to jury trial on all issues present in their action because the remedy of back pay in a duty of fair representation action is legal in nature.

Facts. McLean Trucking Company and the Chauffeurs, Teamsters and Helpers Local Union No. 391 were parties to a collective bargaining agreement. Plaintiffs, Teamsters Local No. 391, were employees of McLean Trucking Company, they object to various employment practices used by McLean Trucking Company (Defendant) that impaired their seniority rights, alleging breach of the collective bargaining agreement. Plaintiffs filed a grievance with the union and the grievance committee. When their seniority rights were impaired again, they filed another grievance, which was refused on the ground that the relevant issues had been determined in the prior proceeding. Plaintiffs filed an action in district court alleging that McLean breached the collective bargaining agreement in violation of Section 301 of the Labor Management Relations Act, and that the Union had violated its duty of fair representation. Plaintiffs requested a permanent injunction requiring the Defendants to cease their illegal acts and to reinstate them to their proper seniority status and sought compensatory damages for lost wages and health benefits. McLean filed for bankruptcy and the action against it was dismissed. Plaintiffs request a jury trial and the Union moved to strike the jury demand on the ground that no right to a jury trial exists in a duty of fair representation suit. The United States Court of Appeals for the Fourth Circuit affirmed the trial court holding that the Seventh Amendment entitled Plaintiffs to a jury trial for their claim for monetary relief.

Issue. Whether an employee who seeks relief in the form of back pay for a union’s alleged breach of its duty of fair representation has a right to a jury trial?

Held. Yes. Judgment is affirmed. In order to determine whether a particular action will resolve legal rights, an examination of the nature of the issues involved and the remedy sought must be conducted. Plaintiffs’ action against Defendants for breach of a union’s duty of fair representation encompasses both legal and equitable issues. The legal issues in this case are comparable to a breach of contract claim. The equitable issues are that of the injunctive relief sought by the Plaintiff to prevent Defendants from continuing to perform their illegal acts. The only remedy sought by the Plaintiff is compensatory damages for back pay and benefits. An award of money damages is a form of legal relief. Thus, the relief sought by the Plaintiff is legal in nature rather than equitable. Therefore, when examining both parts of the Seventh Amendment inquiry, the plaintiffs are entitled to a jury trial on all issues presented in this case.

Dissent. The dissent disagreed with the analytic innovation of the court that identification of the trust action as a model for the duty of fair representation action is insufficient to decide the case. The court must adhere to the historical test in determining the right to a jury trial because it is required by the language of the Seventh Amendment. Concurrence. The Plaintiff seeks a remedy that is legal in nature. The Seventh Amendment entitles Plaintiffs to a jury trial on their duty of fair representation claims. However, Seventh Amendment claims should be determined on the basis of the relief sought. If the relief is legal in nature then the parties have a constitutional right to a trial by jury. By getting rid of the other prong of the Seventh Amendment inquiry, we save the courts from needless an intractable excursions into unfamiliar territory. The concurrence believed that the court made it unnecessarily difficult by exaggerating the importance of finding a precise common law similarity to the duty of fair representation. By stressing the importance of finding an exact similarity the court has diminished the utility of looking for any similarity.

Discussion. The test used by the majority is enumerated in Tull v. Untied States, 481 U.S. 412 (1987). A right to a jury trial exists in actions involving legal issues. In order to determine whether a particular action will resolve legal rights, an examination of the nature of the issues involved and the remedy sought must be conducted. Here, the court determined that Plaintiffs were seeking monetary damages, which is legal relief, as opposed to equitable relief. Therefore, Plaintiffs were entitled to a jury trial.