Conille v. Council 93, No. 18-1038 (1st Cir. 2020)
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The First Circuit reversed the district court's judgment ordering Council 93, a regional division of the American Federation of State, County and Municipal Employees (AFSCME), to reconstitute its executive board "within one year so that there may be proper proportional representation for its constituent locals and members," holding that the district court erred.
This case arose out of a dispute between Council 93 and one of its local divisions, Local 402, over the allocation of seats on Council 93's governing executive board. Plaintiffs, members of Local 402, brought this action alleging that the allocation of seats on the executive board violated their right to an equal vote under Title I of the Labor-Management Reporting and Disclosure act of 1959 (LMRDA) and the AFSCME constitution. The district court agreed and ordered Council 93 to reconstitute its executive board. The First Circuit reversed, holding (1) any remedy for a violation of the equal rights provision of Title I must be implemented by the Secretary of Labor under the remedial provisions of Title IV of the LMRDA; and (2) Plaintiffs failed to show that the union constitution supported their claims.
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