Trbovich v. United Mine Workers
30 L. Ed. 2d 686, 404 U.S. 528, 1972 U.S. LEXIS 148 (1972)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
Title IV of the Labor-Management Reporting and Disclosure Act of 1959 (LMRDA), which establishes suit by the Secretary of Labor as the exclusive post-election remedy, does not bar the intervention of a union member who filed the initial complaint, so long as the intervention is limited to the claims of illegality contained in the Secretary's complaint.
Facts:
- The United Mine Workers of America (UMWA) held an election for its officers on December 9, 1969.
- A member of the UMWA, the petitioner, believed the election was conducted in violation of the LMRDA.
- The petitioner exhausted all available internal remedies under the UMWA's constitution and bylaws.
- Following the exhaustion of internal remedies, the petitioner filed a formal complaint with the Secretary of Labor, alleging numerous violations of the LMRDA occurred during the election.
- The Secretary of Labor investigated the petitioner's complaint and found probable cause to believe that violations of the LMRDA had indeed occurred.
Procedural Posture:
- The Secretary of Labor brought a civil action in the U.S. District Court against the United Mine Workers of America (UMWA) to set aside the 1969 union officer election.
- The petitioner, the union member who filed the initial complaint with the Secretary, filed a motion to intervene in the Secretary's lawsuit.
- The U.S. District Court for the District of Columbia denied the petitioner's motion to intervene.
- The petitioner appealed the denial to the U.S. Court of Appeals for the District of Columbia Circuit.
- The Court of Appeals affirmed the District Court's decision, siding with the UMWA and the Secretary of Labor.
- The petitioner was granted a writ of certiorari by the U.S. Supreme Court.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does Title IV of the Labor-Management Reporting and Disclosure Act of 1959 (LMRDA), which grants the Secretary of Labor exclusive authority to bring a civil action to set aside a union election, prohibit the union member who filed the initial complaint from intervening in the Secretary's lawsuit?
Opinions:
Majority - Mr. Justice Marshall
No, Title IV of the LMRDA does not prohibit the union member from intervening in the Secretary's lawsuit. The statute's exclusivity provision was designed to protect unions from frivolous and multiple lawsuits by centralizing post-election challenges in a single action brought by the Secretary. Allowing a member to intervene in the Secretary's pending suit does not frustrate this purpose, as the Secretary has already screened the complaint for merit and the litigation is already centralized. However, this intervention must be limited to the claims of illegality already presented in the Secretary’s complaint; allowing the intervenor to add new claims would circumvent the Secretary's statutory screening function. Additionally, the member has a right to intervene under Fed. Rule Civ. Proc. 24(a)(2) because the Secretary's duty to represent the broad public interest may not always be identical to the narrower, personal interest of the complaining union member, meaning the member's interest may not be adequately represented.
Dissenting - Mr. Justice Douglas
No, Title IV does not bar intervention, but the Court's limitation on that intervention is incorrect. While I agree that union members should be permitted to intervene in the Secretary's enforcement action, I would also permit them to raise additional grounds for setting aside the election. The Secretary has already fulfilled his screening function by deeming the initial complaint meritorious and initiating the lawsuit. Preventing the intervenor from raising related claims undermines the statutory goal of centralizing all litigation concerning a single election into one proceeding, and the burden on the union to defend against these additional claims within the same suit would be minimal.
Analysis:
This decision clarifies the scope of the LMRDA's "exclusive" remedy provision, carving out a right for individual union members to participate in enforcement litigation. It strikes a balance between Congress's intent to shield unions from harassing lawsuits and the individual member's interest in ensuring democratic union governance. By establishing a precedent for limited intervention, the Court reinforces the role of the individual member in the enforcement scheme while still respecting the Secretary of Labor's primary authority. This ruling ensures that the member who initiates the process is not sidelined and can assist the court, particularly in fashioning a remedy, which can be crucial in complex union election disputes.
