Linda Hoekman v. Education Minnesota, No. 21-2687 (8th Cir. 2022)

Court Description: [Colloton, Author, with Loken and Shepherd, Circuit Judges] Civil case - Civil rights. In these cases Minnesota state employees sued unions seeking monetary relief based on the amount of so-called "fair share" fees that had been deducted from their paychecks for the benefit of the unions. See Janus v. American Federation of State, County, & Municipal Employees, 138 S.Ct. 2448 (2018). The district court granted summary judgment for the unions, and plaintiffs appeal. Held: public-sector unions are entitled to a good-faith defense to liability under Section 1983 if they relied on a then-valid statute to collect fair shares from a non-union member employee before Janus was decided. See also Brown v. American Federation of State, County, and Municipal Employees, No. 21-1640 which the court issues this date. Plaintiffs Buros and Piekarski's claims fail because the unions were private actors and were not acting under color of state law; the district court did not err in awarding certain litigation costs to the unions; the unions were not required to move to dismiss the case, thereby reducing potential costs, rather than wait and file motions for summary judgment.