From our private database of 36,900+ case briefs...

Marquez v. Screen Actors Guild, Inc.

United States Supreme Court

525 U.S. 33 (1998)

Facts

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

The rule of law is the black letter law upon which the court rested its decision. To access this section, please start your free trial or log in.

Issue

The issue section includes the dispositive legal issue in the case phrased as a question. To access this section, please start your free trial or log in.

Holding and Reasoning (O’Connor, J.)

The holding and reasoning section includes:

A "yes" or "no" answer to the question framed in the issue section;
A summary of the majority or plurality opinion, using the CREAC method; and
The procedural disposition (e.g., reversed and remanded, affirmed, etc.).

To access this section, please start your free trial or log in.

Concurrence (Kennedy, J.)

The concurrence section is for members only and includes a summary of the concurring judge or justice’s opinion. To access this section, please start your free trial or log in.

What to do next…

Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 629,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.
Unlock this case brief Read our student testimonials
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.
Learn about our approach Read more about Quimbee

Here's why 629,000 law students have relied on our case briefs:

Written by law professors and practitioners, not other law students. 36,900 briefs, keyed to 984 casebooks. Top-notch customer support.
The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership

Here's why 629,000 law students have relied on our case briefs:

Reliable - written by law professors and practitioners, not other law students
The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
Access in your class - works on your mobile and tablet
36,900 briefs - keyed to 984 casebooks
Uniform format for every case brief
Written in plain English - not in legalese and not just repeating the court's language
Massive library of related video lessons - and practice questions
Top-notch customer support