Feaster v. Yance

Teamsters Locals 639 and 640 (the locals) (defendants) represented workers who provided services for roughly 70,000 schoolchildren in the District of Columbia Public Schools (DCPS). The locals bargained jointly with the DCPS and were covered by the same collective-bargaining agreement (CBA). In 1996, the parties unsuccessfully negotiated for a new CBA to cover the years 1996 to 1999. After a lengthy break, the parties agreed to resume negotiations after school opened in September 1999. The Teamsters demanded the same bonuses and pay raises that employees in other bargaining units had obtained through their negotiations. On January 14, 2000, the Teamsters’ chief negotiator, Phillip Feaster (defendant) told DCPS Superintendent Paul Yance (plaintiff) there would be “a serious disruption to the school system” unless the DCPS agreed to the Teamsters’ demands. Two days later, the members of the locals voted overwhelmingly to strike. Five days later, Yance told Feaster the DCPS was making progress on the bonus question but no funds would be available for raises. Feaster responded that the workers would defer the strike but to expect a “serious work stoppage” on Monday, January 24, if no agreement had been reached by then. On Friday, January 21, Yance and the District of Columbia (D.C.) sued to enjoin the Teamsters’ strike. The superior court issued a temporary restraining order. While the order was in place, the Teamsters distributed a leaflet to parents outlining the dispute and predicting that Yance would “cause major chaos in the school system by forcing workers to strike.” On April 12, the judge issued an injunction enjoining the Teamsters from striking. The judge found the threatened strike would be illegal and cause irreparable injury, and that the balance of harms and public interest favored preventing the strike. The Teamsters appealed, challenging the superior court’s jurisdiction to hear the case and arguing that injunctive relief was inappropriate because the strike was not illegal and the DCPS had unclean hands because it had not bargained in good faith.