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Bowen v. United States Postal Service

United States Supreme Court
459 U.S. 212 (1983)


Facts

When the United States Postal Service (USPS) (codefendant) discharged Charles Bowen (plaintiff), he filed a grievance with the American Postal Workers Union (codefendant), but the union declined to take his grievance to arbitration. Bowen sued USPS and the union seeking reinstatement and backpay, alleging USPS fired him without just cause and that the union breached its duty to provide fair representation. The court instructed the jury to enter a special verdict apportioning Bowen’s damages between USPS and the union. The judge suggested using a hypothetical arbitration date when USPS would have reinstated Bowen had the union processed his grievance, imposing damages before that date on USPS and afterward on the union. The jury returned a special verdict finding USPS fired Bowen without just cause and that the union breached its duty of fair representation, and apportioning damages between them. The court entered judgment accordingly, awarding Bowen $22,594 backpay against USPS and $30,000 against the union. But the appellate court affirmed only the award against USPS, reasoning that the union could not be responsible for lost earnings because only USPS had an obligation to pay Bowen. That left Bowen with a judgment for only $22,594, even though the undisputed amount of wages he lost totaled $52,594. The Supreme Court granted review.

Rule of Law

Issue

Holding and Reasoning (Powell, J.)

Concurrence/Dissent (White, J.)

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