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Local No. 293 of International Alliance of Theatrical Stage Employees v. Local No. 293-A of International Alliance of Theatrical Stage Employees

United States Court of Appeals for the Fifth Circuit

526 F.2d 316 (1976)

Facts

Local 293 (plaintiff) and Local 293-A (defendant) were local unions in New Orleans. Local 293 was a predominantly White union. Local 293-A was a predominantly Black union that had fewer than 10 members. Both local unions were affiliated with the international union known as the International Alliance of Theatrical Stage Employees and Moving Picture Operators of the United States and Canada (IATSE). Local 293-A refused to merge with Local 293. Subsequently, Local 293 brought suit. Local 293 alleged that Local 293-A’s refusal to merge constituted racial discrimination in violation of Title VII of the Civil Rights Act of 1964 (Title VII). The IATSE was not joined as a party defendant. Local 293-A filed a motion to dismiss, which was denied by the district court. Local 293-A appealed.

Rule of Law

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Issue

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Holding and Reasoning (Bell, J.)

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