Union de Empleados de Muelles de Puerto Rico, Inc. v. International Longshoremen's Ass’n, AFL-CIO, No. 16-1372 (1st Cir. 2018)Annotate this Case
On the merits of the remaining portion of this appeal not dismissed as moot, the First Circuit held that the district court properly struck a local union (“UDEM”) as a plaintiff and dismissed this case brought challenging the validity of an international union’s (“ILA”) decision to place UDEM, one of ILA’s affiliates, into a trusteeship after UDEM opposed ILA’s plan to merge it with other local unions.
When UDEM filed suit against ILA, the district court ruled that the trusteeship was lawfully imposed, denied UDEM’s motion for a preliminary injunction against the trusteeship, and struck UDEM as a party on the grounds that it did not have authorization from the trustee to sue ILA. Because the sole plaintiff was stricken, the district court dismissed the complaint. The First Circuit affirmed, holding (1) UDEM’s appeal from the denial of its motion for a preliminary injunction was moot due to the termination of the trusteeship; and (2) on the merits of the remainder of the appeal, UDEM’s vote to disaffiliate before the ILA placed it in trusteeship was invalid under the ILA constitution, and the trusteeship was legally imposed under the Labor-Management Reporting and Disclosure Act, leaving UDEM without authority to bring this lawsuit absent permission from the trustee.