Chauffeurs, Teamsters & Helpers Local No. 391 v. Terry

Background

In 1982, 27 truck drivers who worked for McLean Trucking and were members of the local union were moved to a new terminal, given special seniority, and then repeatedly laid off and recalled in a way they said violated the collective-bargaining agreement. They filed grievances, sued the employer for breaching the contract, and sued the union for failing to represent them fairly, seeking reinstatement and backpay. The employer later went bankrupt, so the drivers pursued money damages only against the union and requested a jury trial. The District Court and the Fourth Circuit allowed a jury; the Supreme Court reviewed the split among circuits and affirmed.

Reasoning

The Court applied the Seventh Amendment test by comparing historical analogs and the nature of the remedy. It found the lawsuit mixed: the union-duty claim resembles a trustee’s equitable claim while the contract claim is legal in character. Because the drivers sought only compensatory backpay (not restitution or relief tied to an injunction), the Court treated the remedy as legal in nature and held the Seventh Amendment entitles them to a jury trial on the money claims.

Real world impact

Workers suing their union for lost pay after claiming unfair representation can demand a jury trial on money damages. Unions defending such claims must prepare for jury fact-finding, which may change litigation tactics and settlement chances. The decision resolves a split among appellate courts and governs lower-court practice.

Dissents or concurrances

Several Justices agreed the drivers should get a jury but disagreed on the test: some would simplify the historical inquiry or favor a malpractice analogy, while a dissent stressed the trust analogy and historical practice against a jury.