Booster Lodge No. 405, International Ass'n of Machinists & Aerospace Workers v. National Labor Relations Board
Headline: Right to resign protected: Court affirms that a union cannot enforce court-collectible fines against workers who resigned before returning to work during a strike, limiting unions’ ability to punish former members.
Holding: Following Textile Workers, the Court held that a union violates the law when it seeks court enforcement of fines against employees who resigned before returning to work during a strike.
- Prevents unions from enforcing court-collectible fines against workers who resigned before returning to strike work.
- Requires reimbursement for fines collected for post-resignation work.
- Limits unions' ability to rely on internal rules to bind ex-members.
Summary
Background
The dispute involved Booster Lodge No. 405, a local union, and the Boeing Company after a lawful strike began the day after their contract expired. During the 18-day strike, 143 of about 1,900 employees crossed the picket line to work. Some of those employees resigned from the union either before or after returning to work. The union held internal trials and imposed standard $450 fines on all employees who worked during the strike, then sent suit papers to collect unpaid fines from several former members. The Company filed a charge with the National Labor Relations Board, and the Board found the union had committed an unfair labor practice by fining and seeking to collect fines from employees who had resigned before returning to work.
Reasoning
The Court applied its earlier decision in NLRB v. Textile Workers and explained that when a member lawfully resigns and then engages in conduct the union proscribes, the union may not seek court enforcement of fines for that post-resignation conduct. The Court found no provision in the union’s constitution or bylaws that clearly limited the right to resign or gave notice that resigning members would still be bound by post-resignation strikebreaking penalties. The Court therefore upheld the Board and Court of Appeals ruling that fining and suing former members for post-resignation work violated the statute.
Real world impact
The ruling prevents unions from using their internal rules to collect court-enforceable fines against workers who left the union before doing the disputed work. The Board’s order required the union to stop such collection efforts and to reimburse any amounts paid that were based on post-resignation work. The decision follows the Court’s prior Textile Workers framework and leaves open questions about situations where resignations are contractually limited or where members had clear notice of post-resignation obligations.
Dissents or concurrances
Justice Blackmun, concurring in the judgment, emphasized that this case differs from Textile Workers because the Boeing employees lacked notice that post-resignation strikebreaking would be punished. He agreed the absence of notice made enforcement improper and joined the Court’s result.
Opinions in this case:
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