Hall v. Cole
United States Supreme Court
412 U.S. 1 (1973)
- Written by Sharon Feldman, JD
Facts
At a membership meeting of the Seafarers International Union of North America (union) (defendant), John Cole (plaintiff) introduced resolutions criticizing union officers. Cole was expelled and brought an action against the union and its president, Paul Hall (defendant) under § 102 of the Labor-Management Reporting and Disclosure Act of 1959 (LMRDA), claiming that the expulsion violated his LMRDA-protected free-speech right. After trial, the district court ordered that the union reinstate Cole and pay his attorneys’ fees. The court of appeals affirmed. The United States Supreme Court granted certiorari. Hall and the union argued that § 102 did not permit an award of attorney’s fees; that even if it did, Congress circumscribed the court’s discretion to award fees by providing other remedies and not expressly authorizing the recovery of fees; and that the court abused its discretion because Cole, motivated in part by ambitions for union office, brought the suit in bad faith, and the union in good faith believed it had a right to discipline Cole.
Rule of Law
Issue
Holding and Reasoning (Brennan, J.)
Dissent (White, J.)
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