Reed v. United Transportation Union
Headline: Union free-speech claims under the LMRDA are governed by state personal-injury time limits, the Court reversed the appeals court and sends the case back for further proceedings under state deadlines.
Holding: The Court held that §101(a)(2) LMRDA free-speech claims are governed by state general or residual personal-injury statutes of limitations, not the NLRA’s six-month period, and reversed the Fourth Circuit.
- State personal-injury deadlines now determine filing time limits for LMRDA free-speech suits.
- Unions and members must check state law, not a single federal six-month rule.
- The decision settles conflicting appeals-court rules about deadlines for these claims.
Summary
Background
A union officer claimed his local union punished him for speaking about union matters and sued under §101(a)(2) of the Labor-Management Reporting and Disclosure Act (LMRDA). The officer waited about two years after his final complaint letters before filing suit. The appeals court said a six-month rule from the National Labor Relations Act (NLRA) should apply. The Supreme Court agreed to resolve a split among appeals courts about which time limit applies.
Reasoning
The Court asked whether a federal six-month rule for unfair labor-practice charges or ordinary state time limits should control suits under §101(a)(2). The Justices concluded that Congress did not set a federal deadline for these free-speech claims and that those claims are most like ordinary personal-injury suits for the purpose of choosing a deadline. Because §101(a)(2) was modeled on free-speech protections, the Court held state general or residual personal-injury statutes of limitations apply, and it reversed the Fourth Circuit.
Real world impact
Going forward, people who bring LMRDA §101(a)(2) suits must look to their state’s usual personal-injury filing deadlines instead of a uniform six-month federal rule. The case was sent back to the lower court for further proceedings consistent with that rule. This decision settles the split among appeals courts about which deadline applies to these union free-speech claims.
Dissents or concurrances
Justice Scalia agreed only with the result, favoring state limits; Justice White dissented, arguing the NLRA six-month rule better serves federal labor policies and should apply.
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