Chauffers Local, 391 v. Terry
494 U.S. 558, 110 S. Ct. 1339, 108 L.Ed. 2d 519 (1990)
The Chauffers Union was
involved in a collective bargaining agreement with McLean Trucking.
McLean began laying people
off, and some of the union workers filed complaints with Chauffers.
Chauffers filed grievances on
two occasions, but declined to do it on the third occasion, claiming the
issue had been settled.
Terry, and other union workers
sued McLean for breaching the collective bargaining agreement, and
Chauffers for violating its duty of fair representation.
McLean filed for bankruptcy
and went out of business, thereby ending the suit against them.
Chauffers made a motion to
strike the jury (aka have a judge decide the case, not a jury) on the grounds that no right to a jury exists in a duty of
fair representation suit.
The Trial Court denied the
motion, Chauffers appealed.
The Appellate Court affirmed. Chauffers appealed.
The Appellate Court found
that the 7th Amendment
entitled the union workers to a trial on their claim for monetary relief.
The US Supreme Court affirmed.
The US Supreme Court noted that suit was being brought
under the National Labor Relations Act, which does not expressly create the duty of fair
The Court found that
the 7th Amendmentpreserves
the right to a trial by jury in suits at common law.
The definition of a suit
at common law is one where legal
rights are to be ascertained and determined, in contradistinction to
those where equitable rights alone are recognized and equitable remedies
Aka, where legal rights are at stake.
The Court looked to
18th Century English Common Law to try to see if a duty for
fair representation suit was legal or equitable.
agreements were illegal in 18th Century England.
Chauffers argued that this
was similar to a trust beneficiary suing a trustee for breach of
fiduciary duty, which was an equity case.
The union workers argued
that this was similar to suing a lawyer for legal malpractice, which was
a suit at law.
The Court felt that
the case involved both equitable and
The Court then
looked to see if the remedy sought would have been considered legal or
equitable back in 18th Century England, and decided that it
The Court found that since the case met both
requirements of the 7th Amendment, the union workers were entitled to a trial by