MacHinists v. NLRB

Background

A local union that represented production and maintenance employees at an aircraft company called a lawful strike after its contract expired. During the 18-day strike, 143 employees crossed the picket line to work; 61 of them resigned from the union before returning and 58 resigned after returning. The union held internal hearings and imposed a standard $450 fine on employees who worked during the strike, then sent some unpaid fines to attorneys and filed state-court suits to collect them.

Reasoning

The main question was whether the union could enforce those fines in court against former members who had resigned before returning to work. The Court applied its earlier decision that employees who lawfully resign are protected in their right to return to work. Because the union’s constitution and bylaws did not clearly limit resignation or give notice that post-resignation strikebreaking would be punished, the Court agreed that seeking court collection of fines for post-resignation work violated the law. The Court affirmed the Board and Court of Appeals findings that such enforcement was an unfair labor practice.

Real world impact

The decision means unions may not turn to state courts to collect fines for strike work by employees who lawfully resigned before returning to work, unless there is clear contractual or prior notice limiting resignation rights. The union still could fine current members for crossing a picket line, and some fines for pre-resignation conduct were not disturbed. The ruling enforces the individual right to resign absent clear, enforceable limits.

Dissents or concurrances

Justice Blackmun, concurring, noted this case differed from a prior one because employees here had no notice of post-resignation penalties; he joined the judgment for that reason.