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Keywords

lawsuitplaintiffdamagesappealtrialcompensatory damagesrespondentjury trial
damagestrialcompensatory damagescommon lawrespondent

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Chauffeurs, Teamsters and Helpers, Local No. 391 v. Terry, 494 U.S. 558, 110 S.Ct. 1339, 108 L.Ed.2d 519, 133 L.R.R.M. (BNA) 2793, 58 USLW 4345, 114 Lab.Cas. P 11,930

Facts

McLean Trucking Company and the Union were parties to a collective-bargaining agreement covering employees. After McLean implemented changes that affected employees' seniority rights, the employees filed grievances with the Union regarding layoffs and recalls. The Union declined to refer the grievances to a committee, leading the employees to file a lawsuit alleging breach of the collective-bargaining agreement and violation of the Union's duty of fair representation, seeking compensatory damages and a jury trial.

McLean Trucking Company and the Chauffeurs, Teamsters, and Helpers Local No. 391 (Union) were parties to a collective-bargaining agreement that governed the terms and conditions of employment at McLean's terminals.

Issue

Whether an employee who seeks relief in the form of backpay for a union's alleged breach of its duty of fair representation has a right to trial by jury.

This case presents the question whether an employee who seeks relief in the form of backpay for a union's alleged breach of its duty of fair representation has a right to trial by jury.

Rule

The Seventh Amendment entitles plaintiffs to a jury trial in suits where legal rights are at stake, particularly when the remedy sought is compensatory damages.

The Seventh Amendment provides that '[i]n Suits at common law, where the value in controversy shall exceed twenty dollars, the right of trial by jury shall be preserved.'

Analysis

The Court analyzed the nature of the issues involved and the remedy sought, concluding that the employees' action encompassed both legal and equitable issues. However, since the only remedy sought was compensatory damages, which are traditionally legal in nature, the Court determined that the employees were entitled to a jury trial.

Our determination under the first part of the Seventh Amendment analysis is only preliminary. Granfinanciera, S.A. v. Nordberg, 492 U.S., at 47, 109 S.Ct., at 2793. In this case, the only remedy sought is a request for compensatory damages representing backpay and benefits.

Conclusion

The Supreme Court affirmed the judgment of the Court of Appeals, holding that the Seventh Amendment entitles respondents to a jury trial on their claim for monetary relief.

We hold, then, that the remedy of backpay sought in this duty of fair representation action is legal in nature.

Who won?

Employees prevailed in the case because the Supreme Court recognized their right to a jury trial under the Seventh Amendment for their claims against the Union.

On balance, our analysis of the nature of respondents' duty of fair representation action and the remedy they seek convinces us that this action is a legal one.

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