Brief Fact Summary. The Respondents, various unionized workers (Respondents), brought action against the Petitioners, Chauffeurs, Teamster and Helpers Local 391 (Petitioners), their union for violation of the duty of fair representation. Respondents sought compensatory damages in the form of back pay and loss of benefits. Respondents requested and were granted a jury trial by the District and Appellate Courts. The Union appealed.
Synopsis of Rule of Law. Claims based on the duty of fair representation are legal in nature.
Because no arbitrator has decided the primary issue presented by this claim, no arbitration award need be undone, even if the employee ultimately prevails.View Full Point of Law
Issue. Whether an employee who seeks relief in the form of back pay for a union’s alleged breach of duty of fair representation has a right to trial by jury.
Held. The nature of Respondents’ duty of fair representation action and the remedy they sought was a legal action. The money damages Respondents sought are of a type traditionally awarded by courts of law. Thus, the Seventh Amendment of the United States Constitution (Constitution), entitled Respondents to a jury trial. Court of Appeals decision affirmed.
Dissent. Supreme Court Justices Anthony Kennedy (J. Kennedy), Sandra Day O’Connor (J. O’Connor) and Antonin Scalia (J. Scalia) asserted that the Seventh Amendment of the Constitution required the Court to determine whether the duty of fair representation action was more similar to cases that were tried in courts of law or in courts of equity. Once the court decided that it was more similar to an equity action (trustee/trust beneficiary), the inquiry should have ended there.
Concurrence. Supreme Court Justice William Brennan (J. Brennan) concurred and said he would rather the test concentrate on the basis of the relief sought rather than looking to see whether historically the action is at law or in equity.
Supreme Court Justice John Paul Stevens (J. Stevens) concurred that the majority made the case difficult by exaggerating the importance of finding a precise common law analogy to the duty of fair representation, which were for the most part in his opinion, ordinary civil actions involving contract and malpractice disputes. He therefore, found no ground for excluding these types of actions from the right to a jury.
Discussion. The Court agreed with the Union’s argument that its duty to the Respondents was analogous to the fiduciary duty that a trustee has to a trust beneficiary – a duty that was traditionally held in equity. However, it had been legally established that the right to a jury trial question depended on the nature of the issue to be tried rather than the overall action. Since the Respondents had to prove that the Union breached its duty of fair representation and that McLean violated the collective bargaining agreement, the action was a legal one, not an equitable one. Further, the Court held that the damages Respondents sought were based on an action of breach of the duty of fair representation and therefore were not solely restitutionary. Thus, an action based on such a claim was legal in nature.