Marquez v. Screen Actors Guild, Inc.
United States Supreme Court
525 U.S. 33 (1998)
Lakeside Productions and the Screen Actors Guild, Inc. (SAG) (collectively, defendants) entered a labor agreement with a standard union-security clause requiring all performers Lakeside hired to obtain SAG membership within 30 days. The clause tracked National Labor Relations Act (NLRA) language exactly, without explaining that “membership” required payment of initiation fees and dues only, not formal membership. Naomi Marquez landed a one-line role in a Lakeside production. Because she had worked in the industry more than 30 days, Marquez had to pay SAG fees of about $500 before production started. Marquez tried to negotiate paying the fees afterward, but a SAG representative told Lakeside’s casting director she had to pay them beforehand. By the time SAG said it would not object to Marquez working in the production, Lakeside had already hired another actress and begun filming. Marquez sued Lakeside and SAG, claiming SAG breached its duty of fair representation. The trial court granted summary judgment against Marquez, and the appellate court affirmed. The Supreme Court granted review.
Rule of Law
Holding and Reasoning (O’Connor, J.)
Concurrence (Kennedy, J.)
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