LeBeau v. Libby-Owens-Ford Co.

Forty-six female employees (female employees) (plaintiffs) brought a class-action suit against their employer Libby-Owens-Ford Co. (LOF), their local union (Local 19), and the international union governing Local 19 (international union) (defendants) for sex discrimination at LOF’s Ottawa, Illinois plant under the Civil Rights Act of 1964. The international union had negotiated a company-wide master agreement with LOF on behalf of union members that set out general rules for wages, conditions, and seniority security, among other topics. The master agreement also expressly allowed individual LOF plants to negotiate plant-specific agreements regarding seniority that varied from the master agreement. Under that provision, LOF’s Ottawa plant and Local 19 negotiated a modified seniority security agreement, under which union members were provided more protection based on seniority than the master agreement. However, those additional protections expressly applied only to male employees, and female employees were only afforded the lesser protections set out in the master agreement. Shortly after the female employees filed suit, the international union was dismissed from the case on the grounds that the international union had not been brought before the Equal Employment Opportunity Employment Commission in the original complaints, among other reasons. Upon the international union’s dismissal, LOF and Local 19 moved to dismiss the matter, claiming that the international union was an indispensable party. The district court granted LOF and Local 19’s motion, and the female employees appealed.