Eldredge v. Carpenters 46 Northern California Counties JATC case brief summary

Eldredge v. Carpenters 46 Northern California Counties JATC (1981)

o    Issue was whether there was a violation of Rule 19?

o    Title VII suit alleging discrimination against women in hiring practice for apprenticeships

o    JATC organized the apprenticeship method

·         Employers chose apprentices from workers that have been referred by JATC

·         Employers had the ultimate decision about whether to hire the apprentices

o    District Court ruled that 4,500 employers must be joined as "indispensable parties" because it is the employers practices that are really at issue; when the Ps. could not join, since it was almost impossible, the district court dismissed the case

o    On appeal à Court reversed – the employers were not indispensable parties under Rule 19(b)

·         The trust fund agreement between the employers and JATC granted full authority to JATC to structure the apprenticeship program and to select the apprentices.

·         Thus, by contract, the employers had ceded to JATC whatever legally protectable interest they made have in selecting apprentices to be trained