United Ass'n of Journeymen & Apprentices of the Plumbing & Pipefitting Industry of the United States & Canada v. Local 334, United Ass'n of Journeymen & Apprentices of the Plumbing & Pipefitting Industry of the United States & Canada

Background

A local union in New Jersey challenged its parent international union after the international ordered a consolidation that split the local’s members into other locals. The local sued in state court to stop the consolidation, the international removed the case to federal court, and lower federal courts disagreed about whether federal law allowed a local to sue its parent over the international’s constitution.

Reasoning

The Court addressed whether a union constitution counts as a “contract between labor organizations” under the Taft-Hartley Act provision that gives federal district courts power over such contract suits. The majority concluded that a union constitution is a contract between labor organizations and that nothing in the statute or its history clearly excludes those documents. The Court therefore held that federal courts have jurisdiction to enforce union constitutions, though it did not decide the exact body of law (state or federal rules) that will govern such suits.

Real world impact

As a result, local unions can bring enforcement claims against parent unions in federal district court when those claims turn on the union constitution. That means more internal union governance disputes may be heard in federal rather than state courts, although the Court left open how courts should decide the underlying legal rules. The ruling does not decide whether individual union members may sue, nor does it resolve all questions about the substantive law to be applied.

Dissents or concurrances

Three Justices dissented, arguing the constitution is a contract only between a union and its members, not between separate labor organizations, and warning that federal courts should not be drawn into ordinary internal union affairs.