Lamb v. Fraternal Order of Police Lodge No. 36Annotate this Case
Plaintiff’s employment as captain in the Washington County sheriff’s office was terminated after an investigation into his conduct. Plaintiff filed suit against the Fraternal Order of Police Lodge No. 36 and Michael Robinson, the County sheriff, alleging (1) as against Lodge No. 36, breach of contract arising from the Lodge’s refusal to provide representation after he requested it, and (2) as against Robinson, interference with a business relationship, alleging that Robinson obstructed the Lodge’s ability to fulfill its duty of fair representation. The district court granted Defendants’ motions to dismiss. The Supreme Court affirmed, holding that the district court (1) did not err in dismissing Plaintiff’s amended complaint for failure to file a grievance and in concluding that it lacked subject matter jurisdiction; and (2) did not err in finding that Plaintiff was immune from suit under the doctrine of sovereign immunity.