Sheet Metal Workers’ International Association v. Lynn

Edward Lynn (plaintiff) was an elected business agent for the Sheet Metal Workers’ International Association Local 75 (the union) (defendant). Lynn and a majority of other union members believed that the way to alleviate the union’s financial problems was to reduce union expenditures rather than increase dues. The membership thrice defeated proposals to increase dues. The union sent a letter to its international association and asked for the union to be placed under a trusteeship for financial management. The international association placed the union under a trusteeship and gave trustee Richard Hawkins the authority to suspend local union officers and business agents. Hawkins decided that an increase in dues was needed and submitted a proposal to the union’s executive board. At a special meeting, Lynn spoke in opposition to the dues-increase proposal, and the proposal was defeated. Thereafter, Hawkins removed Lynn from his position due to Lynn’s opposition to the increase in dues. Lynn sued the union in district court alleging a violation of his free-speech right under the Labor-Management Reporting and Disclosure Act (LMRDA). The district court granted summary judgment for the union under existing caselaw. The Ninth Circuit reversed, highlighting that the dismissed union employee was elected to his position. The matter came before the Supreme Court.