Wooddell v. International Brotherhood of Electrical Workers Local 71

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Court Documents

United States Supreme Court

502 U.S. 93

Wooddell  v.  International Brotherhood of Electrical Workers Local 71

No. 90-967  Argued: Oct. 16, 1991. --- Decided: Dec 4, 1991


Petitioner Wooddell, a member of Local 71 of the International Brotherhood of Electrical Workers (IBEW), sued respondents, the Local and its officers, alleging, inter alia, that, because of his opposition to proposed union actions, they had violated his rights under Title I of the Labor Management Reporting and Disclosure Act of 1959 (LMRDA) by discriminating against him in job referrals in the operation of a hiring hall provided for in the Local's collective-bargaining contracts with electrical contractors. He also contended that such conduct constituted violations of the IBEW Constitution and the Local's bylaws, which were allegedly breaches of contract redressable under § 301 of the Labor-Management Relations Act, 1947 (LMRA). Among other things, Wooddell sought injunctive relief, lost wages and benefits, and damages. The District Court dismissed all claims against all defendants. The Court of Appeals reversed the dismissal of the LMRDA claim but otherwise affirmed the District Court, including its holding that Wooddell had no right to have the LMRDA claim tried to a jury. The Court of Appeals further held that § 301-which provides that "[s]uits for violation of contracts between . . . labor organizations . . . may be brought in . . . district court"-did not authorize a breach-of-contract action to be brought by an individual union member for an alleged violation of a union constitution.


1. Wooddell was entitled to a jury trial on the LMRDA cause of action. Although he seeks injunctive relief as well as damages, the injunctive relief is assertedly incidental to the damages. His claim for lost wages cannot be treated as restitutionary incident to an order reinstating him to a job from which he has been terminated, as the damages sought are for pay for jobs to which the union failed to refer him. Also, an LMRDA action is closely analogous to a personal injury action, a prototypical example of an action at law to which the Seventh Amendment right to jury trial applies. Thus, Teamsters v. Terry, 494 U.S. 558, 565, 570, 571, 110 S.Ct. 1339, ----, ----, ----, 108 L.Ed.2d 519-in which the Court found a right to a jury trial on a claim for an employer's breach of a collective-bargaining agreement under § 301 and a union's breach of the duty of fair representation-controls this case. Pp. 97-98.

2. The subject-matter jurisdiction conferred on the district courts by § 301(a) extends to suits on union constitutions brought by individual union members. Wooddell charged a violation of a contract between unions within the meaning of § 301, since union constitutions are an important form of contract between labor organizations, Plumbers and Pipefitters v. Plumbers and Pipefitters, Local 334, 452 U.S. 615, 624, 101 S.Ct. 2546, 2551, 69 L.Ed.2d 280, and since Wooddell alleged that the IBEW Constitution requires locals to live up to collective-bargaining agreements, that that constitution and the Local's bylaws are contracts which are binding on the Local, and that the defendants had breached such contracts by discriminating against him in referrals. Moreover, § 301 is not limited to suits brought by a party to an interunion contract, but extends to individual union members when they are the beneficiaries of such contracts. Cf. Smith v. Evening News Assn., 371 U.S. 195, 200-201, 83 S.Ct. 267, 270-271, 9 L.Ed.2d 246. If such members could not sue under § 301, but were required to resort to state court and state law, the possibility that individual contract terms might have different meanings under state and federal law would inevitably exert a disruptive influence upon the negotiation and administration of interunion contracts. Cf. ibid. There is no merit to respondents' contention that construing § 301 in this fashion signals an unwarranted intrusion on state contract law, since there is no indication in the later-enacted LMRDA that Congress meant to narrow § 301's reach. Also unconvincing is respondents' submission that this construction of § 301 will inundate the federal courts with trivial suits dealing with intraunion affairs, since there is no evidence of such a result in the various Federal Circuits that have adopted the interpretation. Pp. 98-103.

907 F.2d 151 (CA6 1990) reversed and remanded.

WHITE, J., delivered the opinion of the Court, in which all other Members joined, except THOMAS, J., who took no part in the consideration or decision of the case.

Theodore E. Meckler, Cleveland, Ohio, for petitioner.

Frederick G. Cloppert, Jr., Columbus, Ohio, for respondents.

Justice WHITE delivered the opinion of the Court.


This work is in the public domain in the United States because it is a work of the United States federal government (see 17 U.S.C. 105).