Wholean v. CSEA SEIU Local 2001, No. 19-1563 (2d Cir. 2020)Annotate this Case
A party who complied with directly controlling Supreme Court precedent in collecting fair-share fees cannot be held liable for monetary damages under 42 U.S.C. 1983.
The Second Circuit affirmed the district court's dismissal of plaintiff's Second Amended Complaint, alleging First and Fourteenth Amendment claims brought pursuant to 42 U.S.C. 1983 to obtain repayment of fair-share union fees. The court held that, because defendants collected fair share fees in reliance on directly controlling Supreme Court precedent and then-valid state statutes, their reliance was objectively reasonable, and they are entitled to a good-faith defense as a matter of law. The court reviewed plaintiff's remaining arguments and found them to be without merit.