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Farmer v. United Brotherhood of Carpenters and Joiners, Local 25

United States Supreme Court
430 U.S. 290 (1977)


Facts

Carpenter Richard Hill (plaintiff) was vice president of the United Brotherhood of Carpenters and Joiners, Local 25 (defendant). Disagreement developed between Hill and another union officer over internal policies. According to Hill, the union began discriminating against him in work referrals. After he complained to the international union, Hill was allegedly subject to abuse and harassment. Hill sued in state court for intentional infliction of emotional distress (IIED), discrimination based on union activities, and breach of contract. The court dismissed all but his IIED claim as preempted by federal labor law. At trial, Hill claimed the campaign against him included ongoing public ridicule and verbal abuse, but focused on the union’s giving him only the least desirable work referrals. The court gave no instruction distinguishing between those two types of evidence, and the jury returned a verdict for Hill. The state appellate court reversed, reasoning the lawsuit’s crux involved employment relations and conduct subject only to National Labor Relations Board (NLRB) jurisdiction. Hill died before the case reached the Supreme Court, but the Court granted review and substituted his administrator, Joy Farmer, in his place.

Rule of Law

Issue

Holding and Reasoning (Powell, J.)

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