Utility Workers United Association Local 537 v. Utility Workers Union of America AFL-CIO, No. 22-2142 (3d Cir. 2023)
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Local 537 scheduled a vote to disaffiliate from UWUA and formed a new union, Independent 537. UWUA learned of the impending vote and declared an emergency trusteeship over Local 537. Ninety percent of Local 537 members who cast ballots voted to disaffiliate and to make Independent their new bargaining representative. UWUA President Langford sent notices of the trusteeship to Local 537’s officers and members, stating that all money, books, and property of the Local must be handed over and that all Local Officers were removed. They did not comply. UWUA sought an injunction. The removed officers entered into a consent order and delivered Local 537’s assets.
The NLRB conducted elections and certified Independent 537 as the new bargaining representative. UWUA withdrew its lawsuit, formally lifted the trusteeship, revoked Local 537’s charter, then invoked a section in its constitution permitting forfeiture of assets upon revocation of a local union’s charter and took possession of Local 537’s books, money, and property.
Independent 537 sued under the Labor Management Reporting and Disclosure Act (LMRDA), 29 U.S.C. 401, and the Labor Management Relations Act (LMRA), 29 U.S.C. 141. The Third Circuit affirmed orders granting Independent 537 equitable distribution of Local 537’s assets but denying attorneys’ fees. UWUA breached the fiduciary duty it owed to former Local 537 members under LMRDA section 501, rendering the forfeiture provision unenforceable. Neither the UWUA constitution nor any statute authorizes an award of attorneys’ fees for its breach.
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