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Keywords

contractplaintiffdamagesliabilitymotiondiscriminationcivil rightspunitive damagesbad faith

plaintiffmotioncivil rightsbad faith

Related Cases

Farmer v. ARA Services, Inc., 660 F.2d 1096, 108 L.R.R.M. (BNA) 2145, 26 Fair Empl.Prac.Cas. (BNA) 1068, 26 Empl. Prac. Dec. P 32,068, 92 Lab.Cas. P 12,992

Facts

The case originated from a complaint filed by female employees of Automatic Retailers of America, Inc. (ARA) against both ARA and Local 1064, alleging sex discrimination in hiring and wage practices. The plaintiffs claimed that the union failed to represent their interests adequately in grievance procedures and negotiated contracts that perpetuated discriminatory practices. The district court found that the union had arbitrarily failed to address the grievances of female members and had negotiated agreements that were not adequately explained to the membership.

This action was originally filed by Minnie Farmer, Hyardis Chambers, Shirley Wooton, and Sophie Troshal, on behalf of themselves and a class composed of all persons similarly situated. The plaintiffs, white female employees of Automatic Retailers of America, Inc. (“ARA”), alleged that the company discriminated against them because of their sex by: (1) establishing a hiring, assignment, promotional and seniority system which limited the employment and promotional opportunities of women, and (2) negotiating collective bargaining agreements which provided grossly unequal wage rates to the sex-segregated classifications at ARA.

Issue

Did the union breach its duty of fair representation to its female members and violate the Labor-Management Relations Act and Title VII of the Civil Rights Act?

Rule

A union breaches its duty of fair representation when its conduct toward any member becomes arbitrary, discriminatory, or in bad faith, and it must represent all members fairly and impartially.

A union breaches its duty of fair representation when its conduct toward any member becomes arbitrary, discriminatory or in bad faith.

Analysis

The court found that Local 1064 failed to adequately represent the interests of female employees during negotiations and grievance procedures, which resulted in discriminatory practices being perpetuated. The union's actions were deemed arbitrary and not in line with its duty to represent all members fairly, leading to violations of both the Labor-Management Relations Act and Title VII.

The district court found that Local 1064 arbitrarily failed and/or refused to arbitrate and compromise plaintiffs' legitimate grievances arising under the collective bargaining agreement.

Conclusion

The court affirmed the district court's findings of liability against the union for breaching its duty of fair representation and upheld the awards for back pay and emotional distress, while reversing the punitive damages.

Affirmed in part, reversed in part.

Who won?

The female union members prevailed in the case because the court found that the union had failed to represent their interests adequately and had engaged in discriminatory practices.

The plaintiffs established the futility of going through the union grievance machinery.

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