Monday, May 19, 2014

Local 174, Teamsters, Chauffeurs, Warehousemen Helpers v. Lucas Flour Co. case brief summary

Local 174, Teamsters, Chauffeurs, Warehousemen Helpers v Lucas Flour Co.
 
PROCEDURAL POSTURE: Certiorari was issued to the Supreme Court of Washington to determine whether the Labor Management Relations Act, 29 U.S.C.S. 185, applied in an action in which a state court applied state law to find that petitioner union violated a collective bargaining contract with respondent employer by calling a strike to force respondent to rehire an employee.

OVERVIEW: The judgment finding petitioner union violated a collective bargaining contract by striking to settle a contract dispute was affirmed where the contract called for arbitration to resolve disputes. Respondent fired an employee for unsatisfactory work. Petitioner called a strike to force respondent to rehire the employee. Respondent brought suit in the state trial court, asking for business loss damages. The trial court applied principles of state law and found for respondent where the strike violated the contract and was an attempt to coerce respondent to forgo its contractual right to discharge an employee for unsatisfactory work. Petitioner appealed. The state appellate court affirmed. Petitioner again appealed. The Supreme Court affirmed, holding that although federal labor law pre-empted state law where a conflict existed, affirmance was proper where petitioner violated the agreement despite the absence of a no-strike clause in the contract. A strike to settle a collective bargaining agreement violated the agreement because the agreement called for arbitration proceedings to settle disputes.

OUTCOME: The Supreme Court affirmed the state appellate court's judgment that petitioner union violated a collective bargaining contract with respondent employer. Where the contract required labor disputes to be settled by arbitration, petitioner violated the contract by calling a strike. Although the state court failed to apply federal substantive law, the Court affirmed upon the finding that the contract was violated.

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