Sunday, November 24, 2013

Conley v. Gibson case brief

Conley v. Gibson case brief summary
355 U.S. 42 (1957)

Petitioners, African-American railroad workers, sought review of a decision from the United States Court of Appeals for the Fifth Circuit that affirmed the dismissal of an action under the Railroad Labor Act, 45 U.S.C.S. § 151 et seq., against respondent union where they sought to compel their collective bargaining agent to represent them fairly, and held that the National Railroad Adjustment Board had exclusive jurisdiction over the controversy.

The railroad workers filed a class suit against the union after 45 of them were ousted from their jobs and replaced by Caucasians, and the union failed to give them protection comparable to that given the Caucasian employees. The district court dismissed their case for lack of jurisdiction, and the lower appellate court affirmed the judgment.


  • In reversing the judgment, the Court held that the dismissal of the railroad workers' complaint for lack of jurisdiction was in error because the Board lacked power under 45 U.S.C.S. § 153 or any other provision under the Railroad Labor Act to protect them from the alleged discrimination. 
  • The Court also determined that the railroad workers' employer was not an indispensable party required to be joined because the action was not directly or indirectly against the railroad and because no relief was asked from the railroad or would bind the railroad. 
  • The railroad workers' complaint adequately set forth a claim upon which relief could be granted because there were facts which, if proven, would support the railroad workers' claims and would entitle them to their requested relief.

The Court reversed the lower appellate court's decision and remanded the case for further proceedings not inconsistent with the Court's opinion.

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