Local No. 82, Furniture & Piano Moving Drivers v. Crowley

There was a pending officer election set to occur in December 1980 for Local No. 82, Furniture & Piano Moving Drivers (the union) (defendant). Before the election, several union members were excluded from a union meeting to nominate candidates because the union members could not produce a computerized receipt showing their dues payment. In addition, although challenger John Lynch claimed to have been nominated for the position of secretary-treasurer, ballots distributed to union members named Lynch as a nominee for the position of president. Based on these events, Jerome Crowley and other challenging union members (plaintiffs) sued the union in district court, alleging violations of their rights protected under Title I of the Labor-Management Reporting and Disclosure Act (LMRDA) as follows: (1) violation of equal rights to nominate candidates and attend union meetings and (2) violation of their freedom of expression at union meetings. The district court ordered the distributed and mostly completed ballots to be sealed and delivered to court, preventing a ballot count. Invoking Title I jurisdiction, the court further invalidated the ballots and selected an outside arbitrator to conduct a new election. On appeal, the secretary of labor intervened on the union’s behalf. The court of appeals affirmed the district court’s injunction. The matter came before the Supreme Court.