Pattern Makers' League v. National Labor Relations Board

1985-06-27

Headline: Court upholds ban on unions fining members who tried to quit during a strike, making it harder for unions to enforce strike-resignation rules and protecting workers who return to work.

Holding: The Court ruled that the labor board reasonably interpreted the law to prohibit a union from fining members who tendered resignations invalid under the union’s constitution for returning to work during a strike.

Real World Impact:

Prevents unions from fining members who tried to resign during strikes.
Protects workers who return to work from payoff-style fines.
Limits unions’ ability to enforce no-resignation rules during strikes.

Topics: union discipline, strike rules, labor rights, worker resignation, labor board rulings

Summary

Background

A national labor union adopted a rule (called League Law 13) that barred resignations during a strike or when a strike seemed imminent. Two local chapters in Rockford and Beloit went on strike; about 43 members participated. Eleven members (one in September and ten more later) sent resignation letters and returned to work. The locals rejected those resignations as invalid under the union constitution and fined the returning workers about the amount they had earned on strike. The employers’ association filed charges with the National Labor Relations Board, which found the fines unlawful; the Seventh Circuit enforced the Board’s order, and the Supreme Court reviewed the legal question.

Reasoning

The core question was whether the Board’s reading of the labor law reasonably forbids a union from fining members who tried to resign when the union’s own rules said the resignations were invalid. The Court explained that workers have a statutory right to "refrain" from concerted activities, and punishing those who return to work can unlawfully "restrain or coerce" that choice. The Court gave deference to the Board’s expertise, distinguished older cases allowing internal fines for members who remained free to quit, and concluded the proviso protecting internal union rules does not allow a rule that effectively blocks resignation and then fines those who try to leave.

Real world impact

The decision prevents unions from enforcing strike‑period no‑resignation provisions by fining members who tendered resignations and returned to work. Workers who leave during strikes cannot be fined under federal law; unions must rely on other, lawful measures. The ruling narrows unions’ internal enforcement power and was defended as a reasonable agency interpretation.

Dissents or concurrances

Justice White concurred, emphasizing deference to the Board. Justice Blackmun (joined by Brennan and Marshall) dissented, arguing unions may enforce membership promises to preserve strike solidarity; Justice Stevens also dissented on legislative‑history grounds.