Linda Hoekman v. Education Minnesota, No. 21-1366 (8th Cir. 2022)
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Appellants are four Minnesota state employees who sued unions that represented their local bargaining units. The employees sought monetary relief based on the amount of so-called “fair-share” fees that were deducted from employee paychecks for the benefit of the unions. The district court granted summary judgment in favor of the unions. On appeal, the employees argue that the district court erred by granting summary judgment in favor of the unions on each of the claims for retrospective relief.
The Eighth Circuit affirmed, holding that the unions’ reliance on Section 179A.06 was objectively reasonable. It is an open question whether subjective intent is relevant to the defense, but the employees did not present a submissible case that the unions collected fair-share fees in subjective bad faith in any event. Therefore, the district court correctly granted summary judgment for the unions on these claims.
The unions prevailed on motions for summary judgment. The rules of civil procedure provide those costs “should be allowed to the prevailing party,” unless the court or a federal statute or rule directs otherwise. Further, the employees point to no authority that requires a district court to reduce an award of costs because a defendant opted to forgo a motion to dismiss and to file a dispositive motion only after developing a factual record. A defendant may choose how best to defend a lawsuit, and if the case is resolved in favor of the defense on a motion for summary judgment, then the defendant is presumptively entitled to costs.
Court Description: [Colloton, Author, with Loken and Shepherd, Circuit Judges] Civil case - Civil rights. In these cases Minnesota state employees sued unions seeking monetary relief based on the amount of so-called "fair share" fees that had been deducted from their paychecks for the benefit of the unions. See Janus v. American Federation of State, County, & Municipal Employees, 138 S.Ct. 2448 (2018). The district court granted summary judgment for the unions, and plaintiffs appeal. Held: public-sector unions are entitled to a good-faith defense to liability under Section 1983 if they relied on a then-valid statute to collect fair shares from a non-union member employee before Janus was decided. See also Brown v. American Federation of State, County, and Municipal Employees, No. 21-1640 which the court issues this date. Plaintiffs Buros and Piekarski's claims fail because the unions were private actors and were not acting under color of state law; the district court did not err in awarding certain litigation costs to the unions; the unions were not required to move to dismiss the case, thereby reducing potential costs, rather than wait and file motions for summary judgment.
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