International Organization of Masters, Mates & Pilots v. Brown

Background

An individual member who wanted to run for office in a maritime union asked for the names and addresses of voting members so he could mail campaign literature before the union’s nominating convention. The union’s written rule forbade any preconvention mailings and refused his request. The member appealed inside the union, was denied, sued under a federal law that requires unions to comply with reasonable candidate requests, and won a preliminary injunction in federal court. The Court of Appeals affirmed, and the Supreme Court reviewed the case.

Reasoning

The central question was whether a court must judge the fairness of a union’s internal rule before deciding if a candidate’s request to mail literature is reasonable. The Court held that the statute directs courts to evaluate the candidate’s request itself—because the law requires unions to comply with “all reasonable requests” and does not make that right subject to internal rules. The Court rejected the union’s arguments that preexisting nondiscriminatory rules, concerns about administrative burdens, or respect for internal union procedures should automatically make such requests unreasonable. The union offered no evidence that the requested preconvention mailing would impose costs, administrative problems, or unfair discrimination against other candidates.

Real world impact

As a result, unions cannot rely solely on a rule banning preconvention mailings to deny reasonable distribution requests. Candidates, especially challengers trying to reach members who work away from home, can seek access earlier. A candidate may bring a federal suit to enforce this statutory right when a reasonable request is denied.