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 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 the motion. 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 suit is being brought under the National Labor Relations Act, which does not expressly create the duty of fair representation.
    • The Supreme Court found that the 7th Amendment preserves 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 are administered.
        • Aka, where legal rights are at stake.
    • The Supreme Court looked to 18th Century English Common Law to try to see if a duty for fair representation suit was legal or equitable.
      • Collective bargaining 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 Supreme Court felt that the case involved both equitable and legal issues.
    • The Supreme 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 was legal.
    • Since the case meets both requirements of the 7th Amendment, the union workers are entitled to a trial by jury.