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Chauffeurs, Teamsters and Helpers, Local No. 391 v. Terry

(1990)

Supreme Court of the United States - 494 U.S. 558

tl;dr:

This case demonstrates the two-step test to define the term "common law" in the seventh amendment, and thereby determine when an individual is entitled to a jury trial.

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Case Summary

In the case of Terry v. Chauffeurs, Teamsters and Helpers, Local No. 391 (1990), truck drivers Terry and others sued their labor union for not fairly representing them under the Labor Management Relations Act. The workers believed that their employer, McLean Trucking Company, violated their seniority rights according to the agreement between the company and the union. After the Union refused to help them due to a previous arbitration decision, the workers took the case to federal court.

The Supreme Court decided that the workers had the right to a jury trial as stated in the Seventh Amendment of the Constitution. The court used a two-part test to determine this, looking at the nature of the action and the remedy sought. They found that suing for a breach of fair representation was similar to suing for a breach of contract or fiduciary duty, which usually required a jury trial.

Additionally, the court acknowledged that seeking compensatory damages, like back pay and benefits, was a legal action that should be rewarded by a court of law. The Union's argument that a jury trial would disrupt federal labor policy or undermine arbitration was dismissed by the Court.

This case is significant because it shows how courts use different theories of jurisdiction and choice of law in federal question cases. It also demonstrates the courts' interpretation and application of civil procedure rules, such as Rule 38, which governs jury trials in civil actions.

ICRAIssue, Conclusion, Rule, Analysis for Chauffeurs, Teamsters and Helpers, Local No. 391 v. Terry

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Facts & HoldingChauffeurs, Teamsters and Helpers, Local No. 391 v. Terry case brief facts & holding

Facts:McLean engaged in periodic layoffs and recalls of some of...

Holding:The court applies the two factor test under the Seventh...

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Chauffeurs, Teamsters and Helpers, Local No. 391 v. Terry | Case Brief DeepDive
Majority opinion, author: Justice Marshall
Level 1
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This case involves an employee seeking backpay for a union's alleged breach of its duty of fair representation. The employee filed a grievance with the Union, but the Union declined to refer the charges to a grievance committee. The employee filed a lawsuit in District Court against the employer and the Union, alleging that the employer breached the collective-bargaining agreement and the Union violated its duty of fair representation. The lower court erred in not considering the third grievance filed by the employee. The National Labor Relations Act imposes a duty of fair representation on unions, requiring them to serve the interests of all members without hostility or discrimination. To bring a § 301 action against an employer, an employee must prove that the union breached its duty of fair representation in handling their grievance. The Seventh Amendment guarantees the right to a jury trial in suits at common law where the value in controversy exceeds twenty dollars, which extends to causes of action created by Congress. The duty of fair representation action is not similar to a suit to vacate an arbitration award because the grievance process did not consider the claim that the Union violated its duty of fair representation. The trust analogy more fully captures the relationship between the union and the represented employees than the attorney malpractice analogy.

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Opinion (Concurrence), author: Justice Brennan
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Justice Brennan and Justice Scalia propose different approaches to determine if a claim is a "suit at common law" under the Seventh Amendment. Justice Brennan suggests that the relief sought should be the basis for deciding if a party has a constitutional right to a trial by jury. Justice Scalia argues that the focus should be on the nature of the remedy sought, and the historical analysis should be abandoned unless Congress has delegated the dispute to a specialized decision-maker. The historical test is difficult to apply, and judges lack the training and time for reputable historical scholarship, leading to conflicting decisions. Justice Stewart recognized the difficulties of this task in his dissent in Ross v. Bernhard. Engaging in such inquiries is impracticable and unilluminating.

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Opinion (Concurrence), author: Justice Stevens
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Justice Stevens disagrees with the Court's approach of finding a precise common-law analogue to the duty of fair representation, as it limits the usefulness of finding any analogue. He suggests that the duty of fair representation is more similar to an action against an attorney for malpractice, although it does not have a precise counterpart in 17th- or 18th-century English law. The Court's comparison of the duty of fair representation to an action against a trustee is overstated, as collective bargaining does not involve a settlor, trust corpus, or trust instrument. Equitable reasoning is appropriate for reviewing a trustee's conduct that impacts the future interests of contingent remaindermen, while the commonsense understanding of a jury is appropriate for resolving disputes in employment relationships. In duty of fair representation cases, issues that require an understanding of employment realities are typically decided by a jury.

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Dissenting opinion, author: Justice Kennedy
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The legal case concerns whether the Seventh Amendment guarantees a jury trial for union members in a duty of fair representation action against their labor union. The Court has decided in favor of an equitable action, and Justice Marshall argues that the duty of fair representation action is more similar to an equitable trust action than a suit for malpractice. The case is more akin to a trust action than a legal malpractice action, and therefore, the respondents do not have the right to a jury trial. The author argues that equitable procedures do not determine the right to a jury trial, and the elements of a duty of fair representation action cannot be separated from each other. The passage emphasizes the importance of the remedy available in determining the right to a jury trial and discusses the importance of monetary relief in determining the nature of a statutory action.

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