Stenger v. Bi-State Dev. Agency, No. 15-1338 (8th Cir. 2015)
Annotate this CaseMechanics, members of the Union and employees of Metro, filed a declaratory judgment action, seeking a declaration under section 13(c) of the Urban Mass Transportation Act of 1964 (UMTA), 49 U.S.C. 5333, that Metro must establish a framework through which they could form a bargaining unit separate from the Union. The Union intervened and the district court granted the Union's motion to dismiss for failure to state a claim. The court concluded that the district court correctly determined that section 13(c) does not entitle mechanics to the relief they seek because Congress did not intend to provide a federal forum for disputes between unions and transit authorities; the language and structure of section 13(c) does not suggest that Congress intended to create a federal private cause of action; and the consistent theme in Section 13(c)’s legislative history was that “Congress intended that labor relations between transit workers and local governments would be controlled by state law[.]" Accordingly, the court affirmed the judgment.
Court Description: Wollman, Author, with Colloton and Kelly, Circuit Judges] Civil case - Labor law. In action by mechanics seeking a declaratory judgment under section 13(c) of the Urban Mass Transportaion Act of 1964 that defendant Bi-State must establish a framework through which they could form a bargaining unit separate from the defendant Amalgamated Transit Union, the district court did not err in granting the Union's motion to dismiss for failure to state a claim as section 13(c) does not create a federal private cause of action.
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