Brotherhood of Teamsters, Local No. 70 v. California Consolidators, Inc.

Background

A union that represented workers at one company sued in federal court under a federal law that lets unions enforce collective bargaining contracts. The union said a second company actually functioned as the same employer and so should be bound by the union’s contract. The trial court said it lacked power to decide whether the workers formed the proper bargaining unit. The Ninth Circuit agreed, relying on a prior case that said the National Labor Relations Board should make the first decision about bargaining units. The Fifth Circuit reached the opposite view in a similar case, creating a conflict between appeals courts.

Reasoning

The key question presented was whether federal judges may decide whether employees form an appropriate bargaining unit when the Board has not already ruled. The Supreme Court declined to hear the case and thus left the appeals-court split unresolved. Because the Court denied review, it did not settle whether South Prairie requires deference to the Board whenever a bargaining-unit question arises, or whether such questions can be decided as part of a contract lawsuit.

Real world impact

The denial leaves different regional federal courts applying different rules about who decides bargaining units. Unions, employers, and lower courts remain uncertain about where to bring disputes and which decision-maker will control the outcome. This ruling is not a final national decision and the question could return to the Court later.

Dissents or concurrances

Justice White, joined by Justice O’Connor, dissented from the denial and would have granted review to resolve the split between the Fifth and Ninth Circuits.