Brady v. Int'l Brotherhood of Teamsters, et al., No. 13-2038 (2d Cir. 2014)Annotate this Case
Plaintiff filed suit against defendants alleging that they violated Title I of the Labor-Management Reporting and Disclosure Act (LMRDA), 29 U.S.C. 411 et seq., by denying him membership in IBT Local 817 in retaliation for his complaints about a union member. The district court held that it lacked subject matter jurisdiction because plaintiff pleaded facts affirmatively establishing that he was neither a member nor a member in substance of the union. The court affirmed the judgment of the district court, concluding that plaintiff failed to plead facts establishing that he was even a member "in substance." The court clarified that the LMRDA conferred subject matter jurisdiction over claims brought by members in substance as well as by formal union members.