Mendez v. California Teachers Association

Background

The plaintiffs were teachers in different California school districts who had previously belonged to teachers’ unions. They alleged that they asked to revoke their union memberships and payroll deductions but were told that deductions would continue until the contractual period for revocation, described as a 90-day window around the membership anniversary date.

The plaintiffs asserted two claims under Section 1983, a federal civil-rights statute that allows suits for violations of federal rights by persons acting under state authority. The first claim challenged union-dues deductions under California Education Code section 45060. The second challenged deductions under collective bargaining agreements and was asserted against the union defendants and the superintendents. The plaintiffs alleged that the deductions violated the First Amendment because they lacked clear, affirmative consent to use the money to support union political activity.

The State, the union defendants, and the superintendents filed or joined motions to dismiss the First Amended Complaint. The opinion identifies those motions as Docket Nos. 83, 84, and 88.

Court’s Analysis

For a Section 1983 claim, a complaint must allege both a violation of a federal right and conduct fairly attributable to the state. The court focused on the state-action requirement—the requirement that the challenged conduct be sufficiently connected to the state.

The court found that the plaintiffs had alleged that they signed agreements authorizing union dues deductions for at least one year. In the court’s view, section 45060 merely established an administrative, ministerial process for deducting dues from the pay of employees who voluntarily joined unions and authorized the deductions. The State and the superintendents did not enforce the union membership agreements or determine their terms. The court therefore concluded that the alleged constitutional injury from deductions under section 45060 did not arise from state action.

The court also agreed with the reasoning of other courts that the Supreme Court’s decision in Janus v. AFSCME did not prevent enforcement of union membership and dues-authorization agreements that employees had affirmatively accepted. It further found no alleged connection between the State or superintendents and the unions’ alleged misinformation about the legal consequences of membership and dues agreements. According to the opinion, those allegations could support state-law claims against the unions but did not establish state action for Section 1983 purposes.

The court noted two additional possible grounds for dismissal. It stated that the plaintiffs’ dues deductions had stopped before the hearing, so claims seeking prospective relief could be moot. It also stated that any claim for retrospective relief against the superintendents in their official capacities could be barred by the Eleventh Amendment. The court expressly declined to reach other arguments because they were unnecessary to its decision.

Disposition

The court granted the motions to dismiss and the related joinders. It dismissed the action as to Xavier Becerra; Associated Chino Teachers; California Teachers Association; Fremont Unified District Teachers Association; Hayward Education Association-CTA-NEA; National Education Association; Tustin Educators Association; Valley Center-Pauma Teachers Association; Kim Wallace; Matt Wayne; Gregory Franklin; and Norm Enfield. The plaintiffs had stated that they did not seek leave to amend, and the court granted no leave to amend.

Ron McCowan was the only other defendant identified in the order. He had answered the First Amended Complaint rather than moving to dismiss. The court ordered the plaintiffs and McCowan to submit a joint statement explaining how they wished to proceed by January 28, 2020. The order terminated Docket Nos. 83, 84, and 88.