United Food & Commercial Workers Union Local 751 v. Brown Group, Inc.
1996 U.S. LEXIS 2956, 134 L. Ed. 2d 758, 517 U.S. 544 (1996)
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Rule of Law:
The third prong of the associational standing test, which requires that a suit not need the participation of individual members, is a prudential, judicially-created doctrine, not a constitutional requirement. Therefore, Congress has the authority to abrogate this requirement by statute and grant an association standing to sue for damages on behalf of its members.
Facts:
- Respondent Brown Shoe Company decided to close its plant in Dixon, Missouri.
- On January 17, 1992, Brown Shoe sent a letter to a union representative stating it would permanently lay off 277 employees, with the layoffs beginning on March 20, 1992.
- Petitioner United Food and Commercial Workers Union Local 751 (the union) was the exclusive representative of the affected employees.
- The union alleged that Brown Shoe had already begun laying off employees before sending the January 17 letter and continued to do so through February and March.
- The union claimed these actions violated the WARN Act's requirement to provide 60 days' notice before a mass layoff.
Procedural Posture:
- United Food and Commercial Workers Union Local 751 sued Brown Shoe Company in the U.S. District Court for the Eastern District of Missouri, alleging violations of the WARN Act.
- The District Court granted Brown Shoe's motion to dismiss under FRCP 12(b)(6), holding that the union lacked associational standing to seek monetary relief for its members.
- The union, as appellant, appealed the dismissal to the U.S. Court of Appeals for the Eighth Circuit.
- The Court of Appeals affirmed the District Court's judgment, agreeing that the union could not satisfy the third prong of the test for associational standing because individual participation was necessary to determine damages.
- The U.S. Supreme Court granted the union's petition for a writ of certiorari.
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Issue:
Does a union have associational standing to sue for monetary damages on behalf of its members under the Worker Adjustment and Retraining Notification (WARN) Act, even if the claim for damages would typically require the participation of individual members under the third prong of the Hunt test?
Opinions:
Majority - Justice Souter
Yes. A union has associational standing to sue for damages on behalf of its members under the WARN Act because Congress, by explicitly authorizing such suits, constitutionally abrogated the prudential third prong of the associational standing test. The third requirement of the Hunt test for associational standing—that neither the claim asserted nor the relief requested requires the participation of individual members—is a prudential rule of judicial self-governance, not a constitutional mandate derived from Article III's 'case or controversy' requirement. While the first prong (injury to a member) is constitutional, the third prong is a matter of administrative convenience and efficiency. Because the limitation is prudential, Congress has the authority to override it by statute, which it clearly did in the WARN Act by expressly permitting a 'representative of employees' to sue to enforce the employer's liability to its aggrieved members.
Analysis:
This decision clarifies the crucial distinction between constitutional and prudential standing requirements, specifically within the context of associational standing. By designating the third prong of the Hunt test as prudential, the Court solidified Congress's power to grant standing by statute, even in situations where courts might traditionally deny it for practical reasons, such as when monetary damages are sought for individual members. The ruling empowers organizations, particularly unions, to act as effective representatives in litigation to vindicate their members' statutory rights to damages, thereby streamlining the enforcement of remedial statutes like the WARN Act.
