Satterfield v. Claypole
| Decision Date | 09 December 1993 |
| Docket Number | No. 21585,21585 |
| Citation | 438 S.E.2d 564,190 W.Va. 384 |
| Court | West Virginia Supreme Court |
| Parties | , 145 L.R.R.M. (BNA) 2758 Lowell SATTERFIELD, Plaintiff Below, Appellee, v. Eugene CLAYPOLE, Marion Russell, Gary Jordan, James Rowan, James Slusser, Jerry Miller, John Darcus, and Rick Yanero, Individually and as Representatives and Officials of U.M.W.A. District 31, an Unincorporated Labor Association, and U.M.W.A. District 31, Defendants Below, U.M.W.A. District 31, Appellant. |
Syllabus by the Court
Pursuant to Section 301(a) of the Labor Management Relations Act, 29 U.S.C.S. § 185(a), federal law preempts state law when a union member brings suit against the district or local union based upon alleged violations of the district or local union constitution.
Jacques R. Williams, Hamstead, Hamstead & Williams, Morgantown, for appellee.
Peter F. Dinardi, Morgantown, for appellant.
This appeal involves an alleged breach of employment contract claim by the appellee, Lowell Satterfield, against the officials of United Mine Workers of America District No. 31. Satterfield alleges that the union wrongfully laid him off from his position as assistant compensation director twice during his tenure as an elected official of the district union. Following a jury trial, the appellee was awarded $50,000.00. The union appeals, arguing that the Marion County Circuit Court erred in failing to rule on whether an employment contract existed and in ruling that federal labor law did not preempt state law. The circuit court denied post-trial motions to this effect by order dated July 6, 1992.
In 1985, Satterfield was elected to the position of assistant compensation director for the local office of District 31 of the United Mine Workers of America, a position created by the terms of the district's constitution. His term of office began on June 20, 1985. During the time that he was elected and took office, District 31 was under their third Constitution. Under its provisions, the assistant compensation director was a mandatory position, since the Constitution used the term "shall" when stating that the office of assistant compensation director should be elected by a plurality of the vote. His term of office was four years. The assistant compensation director was also a member of the board of directors.
On September 19, 1985, the fourth Constitution came into effect. In that Constitution, a lay-off procedure for Board members was established in order to reduce costs. Satterfield voted in favor of the lay-off procedure, which was to be done on basis of seniority, although he now attempts to excuse his vote by explaining he did not have advice of counsel when voting. On January 1, 1987, Satterfield was laid off, until March 9, 1987. He was laid off again from November 28, 1987, through June 20, 1989, when his term of office expired.
In its principal assignment of error, the appellant contends that federal law should have preempted state law because of the labor issues involved. We agree. Section 301 of the Labor Management Relations Act (LMRA) establishes federal jurisdiction for "suits for violation of contracts ... between any ... labor organizations (representing employees in an industry affecting commerce as defined in this chapter)." 29 U.S.C. § 185(a) [29 U.S.C.S. § 185(a) ]. The U.S. Supreme Court has held that "a union constitution can be 'a contract between labor organizations' within the meaning of Section 301(a)" (of the Labor Management Relations Act/Taft-Hartley Act). United Association of Journeymen and Apprentices of the Plumbing and Pipefitting Industry of the United States and Canada, AFL-CIO v. Local 334, United Association of Journeymen and Apprentices of the Plumbing and Pipefitting Industry of the United States and Canada, 452 U.S. 615, 620, 101 S.Ct. 2546, 2549, 69 L.Ed.2d 280 (1981).
Plumbers & Pipefitters involved a suit, removed to the federal district court, by a local union against its parent international union to enjoin enforcement of an order requiring the locals to be consolidated as a violation of the international constitution. The court ruled in favor of the international union. The Third Circuit Court of Appeals, raising the issue sua sponte, held that the federal district court lacked jurisdiction because there would not be sufficient impact on labor-management relations or industrial peace. The Supreme Court reversed, stating that prevailing state law viewed union constitutions as contracts. Id. at 621, 101 S.Ct. at 2550. See Machinists v. Gonzales, 356 U.S. 617, 618-19, 78 S.Ct. 923, 924, 2 L.Ed.2d 1018 (1958). The Court held that because union constitutions are "contract[s]" within the plain meaning of § 301(a), and the local and international unions are "labor organizations," the federal district court had jurisdiction under § 301(a) of the LMRA. Plumbers & Pipefitters, 452 U.S. at 627, 101 S.Ct. at 2553.
In particular, the Supreme Court in Plumbers & Pipefitters pointed out that the prevailing state law view that a union constitution was a contract between parent and local unions was "widely held in the States around the time § 301(a) was enacted." Id. at 621, 101 S.Ct. at 2550. (citations omitted). The Court explained that view:
Congress was also concerned that unions be made legally accountable for agreements into which they entered among themselves, an objective that itself would further stability among labor organizations. Therefore, Section 301(a) provided federal jurisdiction for enforcement of contracts made by labor organizations to counteract jurisdictional defects in many state courts that made it difficult or impossible to bring suits against labor organizations by reason of their status as unincorporated associations. See Charles Dowd Box Company v. Courtney, supra, [368 U.S. 502] at 510, 7 L.Ed.2d 483, 82 S.Ct. 519 [at 524] 93 Cong.Rec. 5014 (1947) (comments of Sen. Ball, a floor leader of the bill).... Surely Congress could conclude that the enforcement of the terms of union constitutions--documents that prescribe the legal relationship and the rights and obligations between the parent and affiliated locals--would contribute to the achievement of labor stability. Since union constitutions were probably the most commonplace form of contract between labor organizations when the Taft-Hartley Act was enacted (and probably still are today), and Congress was obviously familiar with their existence and importance, we cannot believe that Congress would have used the unqualified term "contract" without intending to encompass that category of contracts represented by union constitutions. Nothing in the language and legislative history of Section 301(a) suggests any special qualification or limitation on its reach, and we decline to interpose one ourselves.
Id. 452 U.S. at 624-25, 101 S.Ct. at 2551-52 (emphasis added).
However, both the respondents in Plumbers & Pipefitters and in this case argue that § 301(a) jurisdiction was never intended to extend to disputes arising under union constitutions because, as stated in Plumbers & Pipefitters, "the 80th Congress clearly did not intend to intervene in the internal affairs of labor unions." Id. 452 U.S. at 625, 101 S.Ct. at 2552. The Court in Plumbers & Pipefitters disagreed, stating that Id. at 626, 101 S.Ct. at 2552. The Court concluded that Id. at 627, 101 S.Ct. at 2553.
Although Plumbers & Pipefitters determined that union constitutions were within the scope of § 301(a), the court refused to decide whether "individual union members may bring suit on a union constitution against a labor organization." Id. at 627, n. 16, 101 S.Ct. at 2553, n. 16. Thus, we next address the question of whether federal law would preempt under § 301(a) when a union member sues the local or district under its union constitution.
The United States Supreme Court discussed this issue in Wooddell v. International Brotherhood of Electrical Workers, Local 71, et al., 502 U.S. 93, 112 S.Ct. 494, 116 L.Ed.2d 419 (1991). Wooddell involved a union member's suit against the local and its officers, based upon both the local and international constitutions, in District Court, seeking injunctive relief, lost wages, benefits, additional compensatory damages, punitive damages, and attorney fees. The District Court dismissed all claims against the defendants on a summary judgment motion. The United States Court of Appeals for the Sixth Circuit reversed the dismissal of one claim, but otherwise affirmed the district court's dismissals. The Sixth Circuit stated, among other holdings, that § 301(a) did not authorize an action to be brought by an individual union member. On certiorari, the United States Supreme Court reversed and held that the federal district court had subject matter jurisdiction under the "between labor organizations" provision of § 301(a), 29 U.S.C. § 185(a). Section 301(a) provides that "[s]uits for violation of contracts between an employer and a labor organization representing employees in an industry affecting commerce as defined in this chapter, or between any such labor organizations, may be brought in any district court of the United States having jurisdiction of the parties...." 29 U.S.C. § 185(a) (emphasis added).
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