DelCostello v. International Brotherhood of Teamsters

Supreme Court of the United States · 1983 · Federal Courts

Federal CourtsLabor LawStatutes of LimitationsSection 301Duty of Fair Representation§ 301duty of fair representationhybrid claim

Facts

Each case involved employees who claimed their employer violated a collective-bargaining agreement and their union mishandled the grievance or arbitration process in breach of the duty of fair representation. DelCostello filed suit against Anchor Motor Freight and Teamsters Local 557 several months after a joint grievance committee rejected his grievance as meritless and issued a final and binding decision. Flowers and Jones filed suit against Bethlehem Steel and their union more than 10 months after an arbitrator ruled for the employer on their grievances. In both cases, the lower courts treated the claims under borrowed state limitations periods, such as arbitration-vacatur or malpractice statutes.

Issue

What statute of limitations applies to an employee's hybrid suit against an employer for breach of a collective-bargaining agreement and against a union for breach of the duty of fair representation? Specifically, should courts borrow state limitations periods or instead borrow the 6-month federal period in § 10(b) of the National Labor Relations Act?

Rule

Although borrowing state limitations periods is ordinarily the norm when Congress has provided none, courts may borrow a federal limitations period when it provides a closer analogy and when federal policies and the practicalities of litigation make it significantly more appropriate. For hybrid § 301/fair representation suits against employers and unions, the applicable limitations period is the 6-month period in § 10(b) of the National Labor Relations Act.

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In Cleveland, Nora Patel was fired by Lakefront Components, Inc., a fictional manufacturer, after a dispute over seniority rights under a collective-bargaining agreement. Her union, Midstate Fabricators Local 18, processed her grievance but handled it in an allegedly arbitrary and perfunctory way, and the final grievance decision was issued on January 2. Nora sued both the employer and the union in federal court on August 10.

Which limitations period should the federal court apply?

Explanation. When an employee alleges both that the employer breached the collective-bargaining agreement and that the union breached its duty of fair representation in handling the grievance process, the suit is a hybrid § 301/fair representation action. Under the majority rule, courts ordinarily borrow state limitations periods, but they may borrow a federal one when it is a closer analogy and better fits federal policies and litigation practicalities. For hybrid suits, the 6-month period from § 10(b) applies to both the employer and union claims because the two claims are inextricably interdependent.