SEIU, et al v. NUHW, et al, No. 10-16549 (9th Cir. 2013)
Annotate this CaseThis case stemmed from a union dispute involving local union officials who diverted union resources in an attempt to establish a new competing union. At issue on appeal was whether section 501 of the Labor Management Reporting and Disclosure Act (LMRDA), 29 U.S.C. 501, created a fiduciary duty to the union as an organization, not merely the union's rank-and-file members. The court held that it did. Because defendants were not entitled to an authorization defense, the record was sufficient to support the jury's finding that defendants violated their fiduciary duties to UHW under section 501. The district court did not abuse its discretion by excluding irrelevant evidence. The district court properly issued the permanent injunction. The court upheld that district court's interpretation of the verdict form and its denial of defendants' motion to alter or amend the judgment. There was no abuse of discretion in the district court's ruling on the challenge to the special verdict. Accordingly, the court affirmed the judgment.
Court Description: Labor Law. The panel affirmed the district court’s judgment, after a jury trial, in an action under § 501 of the Labor Management Reporting and Disclosure Act against local union officials who diverted union resources in an attempt to establish a new competing local union. The panel held that § 501 creates a fiduciary duty to the union as an organization, not merely to the union’s rank-and- file members. The panel held that in actively attempting to obstruct the international union executive committee’s decision to consolidate all of its California unionized long- term healthcare workers from three different local unions into one, the local union officials breached the fiduciary duty they owed their own union as an organization. This breach involved a pattern of conduct of engaging in dual unionism that was not protected speech. Because this breach contravened the union’s constitution, it could not have been authorized. The panel also held that the district court did not err in excluding evidence, nor in issuing a permanent injunction. In addition, the district court did not err in reading the verdict to impose several liability, and not joint-and-several liability, on the defendants.
The court issued a subsequent related opinion or order on May 22, 2013.
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