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Chism v. Teamsters Local 322

United States District Court, E.D. Virginia, Richmond Division

November 4, 2019

KENNETH CHISM, Plaintiff,
v.
TEAMSTERS LOCAL 322, Defendant.

          OPINION

          JOHN A. GIBNEY, JR., UNITED STATES DISTRICT JUDGE

         Kenneth Chism served as President of the Teamsters Local 322 (the “Local”) from 2011 to 2018. He sued the Local in the General District Court of Henrico County, Virginia, seeking compensation for unpaid wages and benefits under the Local's policy manual. The Local removed the case to this Court, invoking federal jurisdiction under 28 U.S.C. § 1331. The Local argues that Chism's claim falls under § 301 of the Labor Management Relations Act of 1947 (“LMRA”). Chism has moved to remand to state court. Because the LMRA does not govern Chism's claim, the Court lacks subject matter jurisdiction and will grant the motion to remand.

         I. BACKGROUND

         Chism contends that the Local owes him $23, 588.50 for unused sick and personal leave pursuant to the Local's policy manual (the “Policy Manual”). With respect to personal and sick leave, the Policy Manual references the collective bargaining agreement (“CBA”) between the Local and UPS (the “UPS Contract”). Specifically, Article 7 of the Policy Manual states as follows:

Personal holidays and sick days for full-time officers and business agents will be based on the highest rate of any contract negotiated by Local 322. Personal holidays may be taken at any time during the calendar year at their rate of pay and all other language of the UPS contract will apply for sick days and personal holidays.

(Dk. No. 8-1, at 3.)

         Under Article 68 of the UPS Contract, employees receive compensation “at the current rate of pay” for “[a]ll unused sick days.” (Id. at 4.) Under Article 54 of the UPS Contract, employees receive compensation “at their straight time rate for . . . unused personal holidays.” (Id. at 1.) Articles 54 and 68 also contain instructions for determining eligibility for leave benefits.

         The Local argues that the Court has jurisdiction over this case under the LMRA “[t]o the extent Mr. Chism seeks to enforce some term of the referenced contract between Teamsters Local 322 (a labor organization) and UPS (an employer).” (Dk. No. 1, at 3.) The Local further asserts that “[t]he Policy Manual only has legitimacy as an outgrowth of the [b]ylaws, ” and that the bylaws required “approv[al] by the General President of the International Brotherhood of Teamsters.” (Id. at 3, 5.) Chism has moved to remand, arguing that this case “is a garden-variety claim for wages brought by Chism against his employer.” (Dk. No. 4, at 1.)

         II. DISCUSSION [1]

         Section 301 of the LMRA confers federal jurisdiction over disputes involving “violation of contracts between an employer and a labor organization representing employees . . . or between any labor organizations.” 29 U.S.C. § 185(a). “[T]he goal of § 301 . . . is to promote the uniform interpretation of collective bargaining agreements.” Owen v. Carpenters' Dist. Council, 161 F.3d 767, 772 (4th Cir. 1998); Padilla-Gonzalez v. Local 1575, 635 F.Supp.2d 105, 109 (D.P.R. 2009) (“Congress intended for labor contracts to be evaluated under a federal standard in order to avoid conflicting interpretations at the state and federal level that could inhibit the formation of [CBAs].”).

         To decide whether a claim falls under § 301, a court must first determine whether a contract under § 301 forms the basis of that claim. See Caterpillar, 482 U.S. at 394-95. Second, if the claim concerns a contract under § 301, a court must determine whether resolving that claim requires interpreting the contract. Livadas v. Bradshaw, 512 U.S. 107, 125 (1994) (“[T]he mere need to ‘look to' the [contract] for damages computation is no reason to hold the state-law claim defeated by § 301.”).

         A. Contracts Under § 301

         Under § 301 of the LMRA, federal courts have jurisdiction to hear “[s]uits for violation of contracts . . . between . . . labor organizations.” 29 U.S.C. § 185(a). “[T]he word ‘between' in § 301 refers to ‘contracts, ‘not ‘suits.'” Wooddell v. Int'l Bhd. of Elec. Workers, Local 71, 502 U.S. 93, 98 (1991) (quoting Smith v. Evening News Ass'n, 371 U.S. 195, 198 (1962)). “Hence, a suit properly brought under § 301 must be a suit either for violation of a contract between an employer and a labor organization representing employees in an industry affecting commerce or for violation of a contract between such labor organizations.” Id. at 98. Here, the Local points to two documents: (1) the Local's bylaws and (2) the UPS Contract.

         First, the Local argues that its executive board promulgated the Policy Manual pursuant to the Local's bylaws, which were “approved by the General President of the International Brotherhood of Teamsters.” (Id. at 3.) A local union's “constitution and bylaws, ” however, “merely constitute a contract between a local union and its members, and a suit predicated on such a contract . . . does not fall within . . . section 301.” Dashields v. Robertson, 215 F.3d 1318, 2000 WL 564024, at *2 n.2 (4th Cir. May 10, 2000) (table decision).[2] Accordingly, “federal courts lack jurisdiction under § 301 to adjudicate a dispute between an individual member and a union for alleged violations of a local union's constitution or ...


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