Davis v. International Association of Machinists and Aerospace Workers

Background

Andrew Joseph Davis is a member of Machinists Lodge 1781 and works for United Airlines. The opinion states that his employment is governed by a collective bargaining agreement, and that his local union is affiliated with the International Association of Machinists and Aerospace Workers.

Davis’s complaint concerned events at a Local Lodge 1781 meeting on October 12, 2022. He alleged that the union’s trial committee read findings about him to union members and that this conduct was retaliation for an earlier complaint he had filed against the local lodge. He also described an allegedly retaliatory complaint filed by union officer Eric Grogans with the local union and United Airlines, a union trial scheduled for September 29, 2022, and his alleged removal from an elected position without a trial required by the collective bargaining agreement. The opinion says Davis did not specify when he was removed from office.

Davis originally filed the action in state court, and the defendants removed it to federal court. The defendants argued that the complaint included claims involving the union’s duty of fair representation, violations of the collective bargaining agreement, and denial of due process under that agreement. They argued that these claims were completely preempted by federal law. Their motion also appeared to argue that claims based on events before the October 12 meeting were barred by the statute of limitations and that claims against individual union officials were barred by Supreme Court precedent.

Court’s analysis

The court explained the standard for a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint alleges enough facts to state a legally plausible claim. The court noted that insufficient allegations generally warrant an opportunity to amend unless amendment would be futile.

The court did not decide whether the defendants’ preemption, statute-of-limitations, or precedent arguments were correct. Instead, it focused on the lack of clarity in Davis’s claims. Although Davis clarified that his claims were based only on the October 12, 2022 meeting, the court said it still could not determine what claims he was bringing or which claims were directed against which defendants. Without that information, the court could not assess whether Davis had sufficiently alleged facts supporting those claims.

Ruling and next step

The court granted the defendants’ motion for a more definite statement and dismissed Davis’s complaint with leave to amend. If Davis chose to file an amended complaint, the court directed him to clearly state what claims he was bringing, which defendant each claim was against, and what facts supported each claim. The deadline for an amended complaint was March 26, 2025.