Amalgamated Transit Union v. Lovelace
Annotate this CaseWilliam Lovelace was a member of Amalgamated Transit Union, Local 1300 (Local 1300). For three years, Lovelace and David McClure (together with Local 1300, “the Union”) served together as officers on Local 1300’s executive board. When the men ran for reelection, Lovelace was defeated. Lovelace filed a defamation action against the Union, claiming that his defeat was due to allegedly false and defamatory statements McClure made during the campaign. Lovelace sought both compensatory and punitive damages. The Union filed motions to dismiss, asserting that Lovelace was required to exhaust Local 1300’s internal remedies before filing suit. The circuit court denied the motions. The jury ultimately rendered a verdict in Lovelace’s favor. The Union appealed, challenging the trial court’s denial of their motions to dismiss. The Court of Special Appeals affirmed, concluding that Local 1300’s internal remedies were inadequate because they could not provide the monetary damages that Lovelace sought. The Court of Appeals affirmed, holding that when a union member claims that his union and a fellow union member were liable for defamation and seeks monetary damages and the union's internal remedies do not provide monetary damages, the union’s internal remedies are inadequate and the union member is not required to exhaust them.
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