Baisley v. International Association of Machinists and Aerospace Workers, No. 20-50319 (5th Cir. 2020)
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Plaintiff filed suit to invalidate IAM's opt-out procedures as violative of his First Amendment rights, the Railway Labor Act (RLA), and IAM's Duty of Fair Representation. The district court dismissed the action under Federal Rule of Civil Procedure 12(b)(6).
The Fifth Circuit affirmed, finding no constitutional infirmity in the IAM's opt-out procedures under the settled decisions of the Supreme Court and the Fifth Circuit. In this case, the court distinguished the three cases plaintiff presented regarding public-sector unions, Knox v. SEIU, Local 1000, 567 U.S. 298 (2012), Harris v. Quinn, 573 U.S. 616 (2014), and Janus v. AFSCME, Council 31, 138 S. Ct. 2448 (2018), and explained that it is undisputed that applying them to this private-sector dispute would require the court to extend into a new realm. Furthermore, by extension, plaintiff's constitutional avoidance, statutory, and Duty of Fair Representation claims also fail.
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