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

This case concerns how to assess whether the Seventh Amendment provides a right to a jury trial to a litigant asserting (or defending against) a newly created cause of action.

By way of background: at the time of the adoption of the Seventh Amendment, unions were illegal (courts considered them an unlawful restraint of trade, i.e., an antitrust violation).  A century and some decades later, during which time unions became legal, Congress passed the Labor Management Relations Act ("LMRA").  The LMRA governs the relationship between unions and employers.  Pursuant to modern labor law, duly constituted and authorized unions represented employees in negotiations with employers.  The result of the negotiations was a collective bargaining agreement ("CBA").  In the trucking industry, CBAs frequently addressed seniority rights, the rights of workers who had spent more time at the company to receive better treatment than new workers.  In addition, some CBAs created "grievance committees," which were groups with members that the union and the employer appointed, perhaps also including some individuals related to neither party. Depending on the CBA, grievance committees might mediate or arbitrate disputes.  Frequently, individual workers could not raise matters with a grievance committee - only the union could do so.

So, what would happen when a worker wanted their union to raise an issue with the grievance committee, but the union wrongfully refused to do so?  Federal courts held that the worker could sue the union, alleging a breach of a duty of fair representation, which was a fiduciary duty that the union owed the workers to protect their interests.