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Chauffeurs, Teamsters & Helpers v. Terry

Supreme Court of the United States · 1990 · Civil Procedure

Civil ProcedureSeventh Amendmentjury trialhybrid claimhistorical analogSeventh Amendmentjury trialduty of fair representation

Facts

McLean Trucking and the union were parties to a collective-bargaining agreement covering the respondent truckdrivers. After operational changes and layoffs, respondents filed grievances claiming McLean violated the agreement by giving laid-off inactive drivers priority over them and by undermining their special seniority rights; the union later declined to refer a third grievance to the grievance committee. Respondents then sued, alleging McLean breached the collective-bargaining agreement and the union breached its duty of fair representation. After McLean's bankruptcy, respondents dismissed the employer and all injunctive claims, leaving only claims against the union for compensatory damages consisting of lost wages and health benefits.

Issue

Does the Seventh Amendment entitle employees to a jury trial when they seek backpay and benefits from a union for an alleged breach of the duty of fair representation? More specifically, is that remaining claim against the union legal rather than equitable in nature?

Rule

To determine whether the Seventh Amendment guarantees a jury trial, a court compares the action to 18th-century actions in English courts before the merger of law and equity and examines whether the remedy sought is legal or equitable, with the remedy inquiry being more important. In a duty-of-fair-representation action where the plaintiff seeks only compensatory damages for lost wages and benefits from the union, the relief is legal, not equitable, and the plaintiff is entitled to a jury trial.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Warehouse employees in Columbus, Ohio, sued only their union, Buckeye Freight Workers Guild, after the union refused to advance their grievances over shift assignments. The employer had entered liquidation, and the employees dismissed all claims for reinstatement or injunction, seeking only lost wages and lost health-insurance benefits allegedly caused by the union's unfair representation.

Are the employees entitled to a jury trial on their remaining claim against the union?

Explanation. The Seventh Amendment analysis asks both for a historical analogy and for the nature of the remedy sought, with the remedy inquiry more important. Where employees seek only compensatory damages for lost wages and benefits from the union, and the union is not holding specific money that belongs to them, the relief is legal. The majority held that such a remaining duty-of-fair-representation claim carries a jury-trial right.