Davis v. United Automobile, Aerospace & Agricultural Implement Workers

Background

A former union member sued a union, claiming the union violated the member’s rights under section 101 of the Labor-Management Reporting and Disclosure Act. The Eleventh Circuit said the correct time limit to use for the suit is the National Labor Relations Act’s section 10(b) limitation, relying on earlier Supreme Court guidance in DelCostello. Several other appeals courts have disagreed: a Third Circuit decision reached a similar view, while a First Circuit decision said courts should instead borrow time limits from state law.

Reasoning

The main question was simple: which deadline applies when a former member sues a union under the federal law — the federal NLRA deadline or a state law deadline? The Eleventh Circuit followed DelCostello and applied the NLRA’s section 10(b) time limit. The First Circuit reached the opposite answer, creating a clear conflict among appeals courts about the right source for the statute of limitations.

Real world impact

By denying review, the Supreme Court left that disagreement in place. That means whether a former member’s claim is timely can depend on which appeals circuit hears the case. The ruling does not resolve the question on the merits and could be addressed later if the Court agrees to hear the issue in another case, and litigation continues.

Dissents or concurrances

Justice White dissented from the decision to deny review. He explained that the conflict between circuits is important and said he would have granted review to settle whether federal or state time limits govern these claims.