Taaffe v. American Federation of Government Employees, Local 1969

Background

Christopher L. Taaffe was employed by the United States Department of Veterans Affairs and was a dues-paying member and steward of American Federation of Government Employees, Local 1969. Taaffe alleged that, after he requested assistance moving boxes in the union office because of his disability, Christine Schoenbechler instructed him to handle the boxes himself and later suspended him from his steward position. Taaffe also alleged that Scott Mattson, who later became the union’s president, did not properly investigate or address the incident.

Taaffe filed a discrimination charge with the Equal Employment Opportunity Commission and later brought this action under the Americans with Disabilities Act, the Civil Service Reform Act, the Labor Management Reporting and Disclosure Act, and Minnesota law. The defendants moved to dismiss for lack of subject-matter jurisdiction and failure to state a claim.

Civil Service Reform Act preemption

The court held that the Civil Service Reform Act provides the exclusive administrative procedures for claims based on conduct that could be addressed through that statute. Because Taaffe’s claims arose from his suspension as a union steward and involved his union membership, the court concluded that the allegations could support an unfair-labor-practice charge under the Civil Service Reform Act. Taaffe could not bypass that process by describing the same conduct as an Americans with Disabilities Act violation. The court therefore held that the Civil Service Reform Act preempted his attempt to litigate these claims directly in federal court and that the court lacked subject-matter jurisdiction over claims covered by that statute.

Americans with Disabilities Act claims

The court also analyzed the disability claims under the rule requiring a complaint to state a legally plausible claim.

For the claims against the individual defendants, the court held that Taaffe’s amended complaint did not allege that he filed Equal Employment Opportunity Commission charges against Schoenbechler and Mattson. The submitted Equal Employment Opportunity Commission documents also did not establish exhaustion as to those individuals. The court therefore dismissed the Americans with Disabilities Act claim against the individual defendants for failure to sufficiently allege exhaustion of administrative remedies.

For the claim against Local 1969, the court held that Taaffe did not allege an employer-employee relationship with the union or that the union took an adverse employment action against him as his employer. The court therefore dismissed the Americans with Disabilities Act discrimination claim against Local 1969.

The court also dismissed the Americans with Disabilities Act retaliation claim. Taaffe’s complaint stated only that he had asserted his protected disability rights, without explaining the nature or context of the protected activity. The court held that this conclusory allegation did not provide enough factual support for a plausible retaliation claim and that new allegations in Taaffe’s opposition brief could not cure the complaint’s deficiency.

Claims against union officers

Applying the Supreme Court’s decision in Atkinson v. Sinclair Refining Co., the court held that union officers acting in their official capacities cannot be held individually liable for conduct taken on behalf of the union. Because the claims against Schoenbechler, Mattson, and unnamed Local 1969 officers arose from actions allegedly taken in their official union capacities, the court dismissed those claims against the officers in their individual capacities.

Abandoned claims

The defendants moved to dismiss Taaffe’s breach-of-contract claim, Count V, and breach-of-union-constitution claim, Count VI. Taaffe did not respond to the defendants’ arguments directed at those claims. Relying on Eighth Circuit precedent, the court treated his failure to respond as abandonment and forfeiture. The court dismissed Count V and Count VI with prejudice.

Disposition

The court granted the defendants’ motion to dismiss and ordered judgment to be entered. The opinion expressly states that Counts V and VI were dismissed with prejudice. It does not state that the other claims were dismissed with prejudice.