Brief Fact Summary. The Petitioner in this matter was the Chauffuers, Teamsters, and Helpers Local Union No. 391 (Petitioner). McLean Trucking Company (McLean) and the Petitioner were parties to a collective bargaining agreement. After the Petitioner failed to prosecute one of McLean’s claims, the Respondents, Terry and other workers (Respondents), sought relief in federal court, insisting on a jury trial.
Synopsis of Rule of Law. An action for back pay by a party to a collective bargaining agreement alleging unfair representation is entitled to a jury trial under the Seventh Amendment of the United States Constitution (Constitution).
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 trial by jury.
Held. Yes. A majority of the Supreme Court held that the Seventh Amendment of the constitution entitles such a plaintiff to a jury trial. The court first examines the remedy sought and determines whether it is legal or equitable or nature. The Seventh Amendment constitutional question depends on the nature of the issue to be tried rather than the character of the overall action. The remedy sought by Respondents is legal. The money damages Respondent seeks are the type of relief traditionally awarded by courts of law.
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
Discussion. Students must understand the distinction the majority’s opinion makes between actions at equity and actions at law. A jury need not decide actions at equity. To the contrary, actions at law are entitled to a jury trial. Whereas an action at equity is largely restitutionary, the right to a jury trial in a statutory action depends on the presence of legal rights and remedies, i.e. an action at law.