Eric Brown v. AFSCME, No. 21-1640 (8th Cir. 2022)

Court Description: [Colloton, Author, with Loken and Shepherd, Circuit Judges] Civil case - Civil rights. In these cases, current and former Minnesota state employees sought damages under Section 1983 for money deducted from their paychecks by unions that represented their local bargaining unit. The district court held that the unions were entitled to a defense against liability under Section 1983 because they acted in good-faith reliance on state statutes and existing judicial precedent. For a similar case, see today's decision in Hoekman v. Education Minnesota, No. 21-1366. A plaintiff who sues a private-party defendant based on the defendant's employment of a state law that has been declared unconstitutional must show that the defendant was not acting in good-faith reliance on that law; here, the plaintiffs do not allege that that the unions subjectively believed they were violating the rights of employees by collecting the fees, so the court need not address whether such a showing would overcome the unions' objectively reasonable reliance on the statute in question; because the unions collected the fair share fees under Minn. Stat. Sec. 179A.06 at a time when the procedure used had been deemed constitutional by the Supreme Court, their reliance on the statute was objectively reasonable, and they were entitled to a good-faith defense.