Baker v. General Motors Corp.

Background

A group of General Motors hourly workers stopped receiving unemployment benefits after Michigan concluded they had financed strikes by paying special emergency union dues. The United Automobile Workers had imposed large extra dues during a 1967 bargaining emergency. Short strikes at three foundries used funds collected from those dues and temporarily idled many workers at other GM plants, who then filed for unemployment benefits and lost after state administrative and court proceedings.

Reasoning

The central question was whether federal labor law’s protection for union activity (the right to organize and support union action) prevents a State from denying benefits to people who helped fund a strike. The Court reviewed the Michigan Supreme Court’s detailed finding that the emergency dues were collected for the purpose of supporting strikes, were large in amount, and were used in close time proximity to the strikes that caused layoffs. Relying on earlier decisions about state discretion over unemployment programs, the Court held that Michigan’s financing disqualification — as the state interpreted it — does not violate the federal labor law and affirmed the denial of benefits.

Real world impact

The ruling means that, under these facts, workers who voluntarily provide significant special strike funding can be treated like strikers for unemployment purposes and denied benefits. The Court limited its decision to special or emergency dues and did not approve denying benefits when ordinary, regular union dues are used. The decision leaves room for different state rules and for future challenges about how broadly a state may apply a financing disqualification.

Dissents or concurrances

Justice Brennan dissented, warning the Michigan rule is overbroad and conflicts with federal labor protections unless limited to payments specifically intended to finance the particular strike that caused an individual’s unemployment.