DelCostello v. International Brotherhood of Teamsters
462 U.S. 151, 1983 U.S. LEXIS 51, 76 L. Ed. 2d 476 (1983)
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Rule of Law:
The six-month statute of limitations from § 10(b) of the National Labor Relations Act governs an employee's hybrid suit alleging an employer's breach of a collective bargaining agreement and a union's breach of its duty of fair representation.
Facts:
- In the first consolidated case, Philip DelCostello, a driver for Anchor Motor Freight, Inc., was discharged on June 27, 1977, after refusing to drive a truck he contended was unsafe.
- DelCostello's union, Teamsters Local 557, filed a grievance on his behalf pursuant to the collective-bargaining agreement.
- A joint union-management committee conducted a hearing and concluded that DelCostello's grievance was without merit.
- DelCostello was informed of this final and binding decision in a letter dated August 19, 1977.
- In the second consolidated case, Donald Flowers and King Jones, welders for Bethlehem Steel Corp., filed grievances in 1975 and 1976.
- They alleged the employer violated the collective-bargaining agreement by assigning welding work to employees in other departments, resulting in their layoffs.
- Their union, Steelworkers Local 2602, processed the grievances and invoked arbitration after failing to reach a resolution.
- On February 24, 1978, an arbitrator issued a final award in favor of the employer, ruling the job assignments were permitted by the agreement.
Procedural Posture:
- In the first case, Philip DelCostello sued his employer, Anchor Motor Freight, and his union, Teamsters Local 557, in the U.S. District Court for the District of Maryland.
- The District Court initially denied respondents' motion to dismiss but later granted them summary judgment, applying a 30-day Maryland statute of limitations for vacating arbitration awards.
- The U.S. Court of Appeals for the Fourth Circuit affirmed the District Court's judgment.
- In the second case, Donald Flowers and King Jones sued their employer, Bethlehem Steel, and their union, United Steelworkers, in the U.S. District Court for the Western District of New York.
- The District Court dismissed the suit as untimely under New York's 90-day statute for vacating arbitration awards.
- The U.S. Court of Appeals for the Second Circuit initially reversed, but on remand from the Supreme Court, it affirmed the dismissal against the employer but reversed as to the union, applying a 3-year state malpractice statute.
- The U.S. Supreme Court granted certiorari in both cases and consolidated them for review.
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Issue:
Does the six-month statute of limitations from § 10(b) of the National Labor Relations Act govern an employee's hybrid suit against an employer for breach of a collective bargaining agreement and against a union for breach of its duty of fair representation, rather than a statute of limitations borrowed from state law?
Opinions:
Majority - Justice Brennan
Yes. The six-month statute of limitations prescribed by § 10(b) of the National Labor Relations Act governs a hybrid § 301/fair representation claim. When federal law provides no express statute of limitations, courts typically borrow the most analogous state statute. However, state statutes are inappropriate here because they conflict with federal labor policy. State statutes for vacating arbitration awards are typically too short (e.g., 30-90 days), failing to provide an unsophisticated employee with enough time to recognize the union's breach, retain counsel, and file suit. Conversely, state statutes for legal malpractice are too long and would undermine the federal policy favoring rapid resolution of labor disputes. The six-month period in § 10(b) for filing unfair labor practice charges provides a closer analogy and strikes the proper balance between an employee's interest in vindicating their rights and the national interest in stable bargaining relationships and finality of private settlements.
Dissenting - Justice Stevens
No. The Court should adhere to the traditional practice, grounded in the Rules of Decision Act, of borrowing analogous state statutes of limitations. Nothing in the National Labor Relations Act requires or provides for the application of a different limitations period. The proper approach is to apply the state statute of limitations for legal malpractice to the employee's claim against the union for breach of the duty of fair representation. For the claim against the employer, the Court should follow its precedent in United Parcel Service, Inc. v. Mitchell and apply the state statute for vacating an arbitration award.
Dissenting - Justice O'Connor
No. The longstanding norm is to borrow state statutes of limitations, based on the presumption that Congress intends this practice by its silence. There are no indications strong enough in this context to depart from that usual rule. The court should therefore look to state law. The closest state-law analogy for an employee's suit against a union for breach of the duty of fair representation is an action for legal malpractice, and the state's statute of limitations for such an action should apply.
Analysis:
This decision establishes a significant exception to the general rule of borrowing state statutes of limitations for federal causes of action. By creating a uniform, national six-month statute of limitations for hybrid § 301/fair representation claims, the Court prioritized federal labor policy goals of finality and stability over the traditional deference to state law. This ruling provides clarity and consistency for these common lawsuits, which were previously subject to widely varying time limits depending on the state. It signals that where federal law provides a close substantive analogy and strong federal policies are at stake, courts may borrow from federal rather than state law to fill statutory gaps.
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