Carpenters v. Metal Trades

In 2008, the Building Trades, an umbrella labor organization, launched the "Push-Back-Carpenters Campaign" to force the Carpenters to reaffiliate with the Building Trades. The Building Trades then enlisted the Metal Trades to expel the Carpenters from its membership. The Carpenters subsequently filed suit alleging that the Metal Trades, both by itself and through its non-party affiliates, breached the federal duty of fair representation. The district court dismissed the Carpenters' complaint and amended complaint for failure to state a claim. The court held that a union's selecting stewards from whom it might expect undivided loyalty is not unreasonable discrimination and does not, without more, breach the duty of fair representation. In this case, the Carpenters failed to allege that the Metal Trades removed Carpenters' members from positions as stewards for any reason other than union affiliation. Even if the Metal Trades singled out Carpenters-affiliated workers because of their union affiliation, the Carpenters' complaint fails to state a breach of the duty of fair representation as a matter of law. Accordingly, the court affirmed the district court's judgment. View "Carpenters v. Metal Trades" on Justia Law