Felter v. Southern Pacific Co.

1959-04-27

Headline: Railroad worker wins: Court strikes down union-employer rule forcing use of union‑supplied revocation forms, allowing employees to stop payroll dues deductions by written notice to employer after one year.

Holding: The Court held that the Railway Labor Act lets an employee revoke a dues checkoff by a writing furnished to the employer after one year, and a union‑employer contract cannot require only union‑provided revocation forms.

Real World Impact:

Lets railroad employees revoke payroll dues deductions by written notice to employer.
Prevents unions and employers from adding extra procedural hurdles to revocations.
Affects how checkoff procedures are set in union-employer contracts.

Topics: union dues, payroll deductions, worker rights, railroad labor

Summary

Background

A railroad employee who had authorized payroll deductions for union dues decided, after more than a year, to join a different union and sent written revocation forms to his employer and to his old union. The employer and the Brotherhood of Railroad Trainmen refused to accept those forms, saying the contract required revocations to be on union‑provided cards sent by the union. The employee sued under the Railway Labor Act seeking a declaration and an injunction.

Reasoning

The Court examined the 1951 change to the Railway Labor Act that allows checkoff arrangements but expressly says any individual assignment must be revocable in writing after one year. The majority held that Congress reserved the employee’s individual choice and did not authorize employers and unions to add extra procedural conditions. A simple writing from the employee to the employer that clearly revokes the assignment suffices, and a collective agreement cannot nullify such a revocation by insisting on only union‑provided forms.

Real world impact

The decision protects workers who want to stop automatic dues deductions and prevents unions and employers from creating extra paperwork barriers to revocation. Railroad employers may still guard against fraud, but they cannot treat clear revocation writings as invalid simply because the union’s contract prescribes a different form. The Court reversed the lower courts and invalidated the contractual restriction.

Dissents or concurrances

Three Justices dissented, arguing the contract procedure was practical, the petitioner could have signed the union form to avoid deductions, and courts should not grant extraordinary equitable relief for what they saw as a trivial dispute.