Taylor v. International Union of Painters and Allied Trades

Background

William Taylor, a journeyman member of the International Union of Painters and Allied Trades (IUPAT), sued IUPAT and six union officials under Section 501 of the Labor Management Reporting and Disclosure Act of 1959 (LMRDA). That provision allows a union member to sue over alleged breaches of union officials’ fiduciary duties, including duties to use union property for the organization and its members and to follow the union’s governing documents.

Taylor’s second amended complaint also asserted claims under other LMRDA provisions. The court had previously dismissed Claims Three, Four, Five, and Twelve, while allowing Claims One, Two, Six, Seven, Eight, Nine, Ten, and Eleven—all Section 501 claims—to proceed through discovery. Defendants then moved for summary judgment, which is a ruling entered when the evidence shows that no important factual dispute requires a trial and the moving party is entitled to judgment under the law.

Claims One and Two: Audit and financial reporting

Taylor alleged that union officials failed to provide required financial reports and failed to arrange an audit of the Joint Apprentice Training Committee (JATC). The court found that the IUPAT Constitution did not require the defendants to initiate the requested audit. It also found that the JATC was a separate entity from IUPAT, District Council 36, and Local Union 510, meaning that a Section 501 claim could not be based on the alleged harm to that separate training fund.

The court rejected Taylor’s argument that the officials personally benefited because they received compensation while not ordering the audit. Because the court found that the officials had no constitutional duty to order the audit, it held that their compensation was not an improper benefit. The court also found that Taylor’s general financial-reporting allegations were unsupported by sufficient evidence. His declaration and two letters offered conclusions but no specific evidence showing that the defendants violated the cited constitutional provisions. Summary judgment was therefore granted on Claims One and Two.

Claims Seven, Nine, and Ten: Bylaw referenda

Taylor alleged that the union violated notice and voting requirements for several bylaw referenda. The relevant constitutional provisions required that notice be sent by mail at least 15 days before the meeting at which members would vote. The court interpreted that requirement as requiring the union to mail the notice 15 days in advance, not ensuring that each member physically received it 15 days before the vote.

The court found that the union mailed the notices 15 days before the challenged votes and provided the exact text on which members would vote. It also found no evidence that the referendum locations violated the constitution or were selected in bad faith. The court gave deference to the officials’ interpretation because it was not patently unreasonable or adopted in bad faith. Summary judgment was granted on Claims Seven, Nine, and Ten.

Claims Eight and Eleven: Contract ratification

Taylor challenged two collective-bargaining-agreement ratification votes. He argued that five days’ notice for the April 17, 2021 vote and seven or eight days’ notice for the March 30, 2022 vote were insufficient. He also argued that the first vote was not held at a properly called special meeting and that the votes violated a local COVID-19 health order.

The court held that the applicable IUPAT Constitution provisions required reasonable notice, not a fixed 15-day period. It found that five days’ notice was reasonable and that eight days’ notice for the second vote complied with the constitution. The court also accepted the General President’s interpretation that the first vote was a special meeting and did not require a quorum. Finally, because the health order had been lifted, the court held that Taylor’s request for relief based on an alleged violation of that order was moot. Summary judgment was granted on Claims Eight and Eleven.

Claim Six: Speech at union meetings

Taylor alleged that union officials interfered with his speech at union meetings. The relevant incident involved Vice-President McBride saying, “Can’t we shut him up?” while Taylor was speaking at a February 3, 2022 meeting. Taylor asked for a point of order, and Collins called the meeting to order. Taylor was then able to speak at that and later meetings.

The court held that the incident did not establish a violation of the union constitution or a breach of fiduciary duty supporting a Section 501 claim. It also found no evidence that Collins acted in bad faith by not bringing internal charges. Because the constitution did not specifically prohibit the conduct and the officials’ decisions were not shown to be in bad faith or patently unreasonable, the court granted summary judgment on Claim Six.

Disposition

Judge William H. Orrick concluded that there were no disputed material facts requiring trial. The court granted defendants’ motion for summary judgment as to Claims One, Two, Six, Seven, Eight, Nine, Ten, and Eleven. Because those were the only remaining claims, the court ordered judgment entered accordingly.