Taylor v. International Union of Painters and Allied Trades

Background

William Taylor asked for permission to file a claim under Section 501 of the Labor-Management Reporting and Disclosure Act, a federal law governing fiduciary duties of labor-organization officers. The court had previously denied Taylor’s application because he had not shown good cause to begin litigation over what appeared to be a dormant internal union proceeding. The court allowed him to amend if the proceeding produced an adjudication supporting his request or if he could provide other facts supporting his claim.

Taylor’s amended application relied in significant part on internal union disciplinary charges brought by Clayton McBride. The charges alleged that Taylor violated the International Union of Painters and Allied Trades Constitution in seven ways connected to Taylor’s earlier lawsuit. The defendants showed that McBride requested withdrawal of the charges and that the union withdrew them.

Court’s Analysis

Section 501(b) allows an individual labor-organization member to sue an officer for violating fiduciary duties only after certain prerequisites are met. The organization or its governing board must have failed or refused, within a reasonable time after being asked, to seek appropriate relief. The member must also file a verified application and obtain the court’s permission after showing good cause.

The court found that the withdrawn disciplinary charges could not support Taylor’s amended application. It also found that Taylor’s additional allegations were conclusory and did not show good cause. Taylor alleged that Clayton McBride, Luis Robles, Steve Bigelow, and James A. Williams, Jr. violated fiduciary duties, violated the union constitution, and took over the union’s administration, but he did not identify the constitutional provisions allegedly violated. The court said these allegations mirrored claims it had already found meritless in the earlier case.

Taylor also alleged that he requested information from the union and that the union’s general counsel responded inadequately. The court found that Taylor did not identify the constitutional provision involved or explain how the alleged deficiency created a claim against the defendants he named.

Disposition

The court determined that Taylor had not shown good cause to begin litigation over the terminated internal proceeding or the other disputes described in his application. It stated that Taylor’s prior claims had already been fully litigated and decided and that the new allegations did not provide a foundation for a new lawsuit. The order first states that the amended application was “DISMISSED WITH PREJUDICE,” and later states that it was “DENIED with prejudice” and that the matter would be dismissed. The court entered the order on January 23, 2024.

Classification

This is a procedural order because the court decided whether Taylor had met the statutory prerequisites for permission to file the lawsuit, rather than deciding the underlying fiduciary-duty claims on their merits.