Section 9 Motor Coach Employees v. Lockridge

• Library: Emp-Emp Law 2000

The reason for quoting at length from Vaca v. Sipes, 386 U.S. 171 (1967), becomes apparent when its ruling is compared with that in Amalgamated Ass’n of Street, Electric Railway & Motor Coach Employees of America v. Lockridge, 403 U.S. 274 (1971). Like Vaca, Lockridge involved an issue of whether the state court had jurisdiction over an employee’s claim against a union. Lockridge had sued in Idaho courts and obtained a judgment for $32,678 because he had been discharged at the union’s request, allegedly in violation of the union security clause in the collective bargaining agreement. In attempting to avoid the preemption argument of the union, Lockridge took the position that his state court pleading stated a claim that the union had violated its duty of fair representation. Under Vaca, the state court would have had concurrent jurisdiction.

The Supreme Court held Lockridge’s claim was preempted and that the evidence adduced at trial was not sufficient to prove a fair representation violation. In describing what Lockridge needed to prove, the Court held: “For such a claim to be made out, Lockridge must have proved ‘arbitrary or bad-faith conduct on the part of the Union.’ Vaca v. Sipes, supra, at 193. There must be ‘substantial evidence of fraud, deceitful action or...