ABF Freight Sys. v. Int'l Brotherhood of Teamsters, et al., No. 11-1159 (8th Cir. 2011)
Annotate this CaseABF sued YRC, the International Brotherhood of Teamsters and two of its locals (collectively, Union), and the bargaining representatives of YRC and the Union (collectively, defendants) for violation of a collective bargaining agreement. At issue was whether the district court properly dismissed ABF's complaint for lack of subject matter jurisdiction, ruling that ABF lacked standing to sue because it did not show by a preponderance of the evidence that it had rights under the collective bargaining agreement. The court held that ABF had constitutional standing where it satisfied each element necessary to demonstrate an injury-in-fact to a judicially cognizable interest and that the injury was fairly traceable to defendants' challenged conduct. The court also held that because the district court had original jurisdiction, the district court had subject matter jurisdiction over ABF's claims. The court further held that the case did not turn on primarily representational issues but whether defendants breached any contractual duties to ABF. The court finally held that the district court's Federal Rule of Civil Procedure 12(b)(1) ruling resolved factual issues that courts could not resolve on motions under Rule 12(b)(6) and did not provide proper notice of such a conversion. Accordingly, the district court's judgment was vacated and remanded for further proceedings.
Court Description: Civil case - Labor Law. The District Court erred in finding ABF lacked standing to bring a Labor Management Relations Act Section 301(a) challenge to amendments to the National Master Freight Agreement; ABF clearly had constitutional standing because it has rights under the agreement and could show that defendants' breach of the agreement created an injury-in-fact that is fairly traceable to the challenged acts of the defendants and likely redressable in court; because the court had original jurisdiction over ABF's 301(a) action against the union, the court also had supplemental jurisdiction over ABF's claims against defendant YRC; NLRB does not have exclusive jurisdiction in the case because ABF's claims are not primarily representational in nature.
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