Steele v Louisville & Nashville Railway Co
| Steele v Louisville & Nashville Railroad Co | |
|---|---|
| Court | US Supreme Court |
| Citation(s) | 323 US 192 (1944) |
| Keywords | |
| Preemption | |
Steele v Louisville & Nashville Railroad Co 323 US 192 (1944) is a US labor law case, concerning the right to equal treatment in labor unions for everyone to gt labor rights.
Facts
Steele was an employee in Alabama of the Louisville & Nashville Railroad Co, and a member of the Brotherhood of Locomotive Firemen and Enginemen, a majority white union. The union, without notifying any of the black employees, including Steele, gave the employer a notice that it wished to amend the collective agreement to exclude black staff members, that only white firemen only should be promoted and assigned to permanent jobs. The eventual agreement was no more than 50% of firemen staff should be black. Mr Steele, who had worked in a desirable ‘passenger pool’ job, lost his position and was forced to shift to a worse job. He petitioned for breach of statutory duty, for the union not representing black employees, simply because of their race. Supreme Court of Alabama held there was no violation, because the Act did not require expressly any regard for the specific interests of minorities.
Judgment
The Supreme Court held that under the Railway Labor Act, as an exclusive bargaining representative a union was obliged to represent all employees without discrimination, in the same way the Constitution requires equal protection by the legislature of every citizen. There is a duty to represent minorities, by considering their requests and views, and give notice of and opportunity for hearing about its actions.
Stone CJ gave the court’s judgment.
| “ | Congress, in enacting the Railway Labor Act and authorizing a labor union, chosen by a majority of a craft, to represent the craft, did not intend to confer plenary power upon the union to sacrifice, for the benefit of its members, rights of the minority of the craft, without imposing on it any duty to protect the minority. Since petitioner and the other Negro members of the craft are not members of the Brotherhood or eligible for membership, the authority to act for them is derived not from their action or consent, but wholly from the command of the Act.’
The wording of the Act, speaking of whole classes of workers, and the purposes of the Act, to regulate commerce and so on, would not be achieved if a large minority could be excluded from protection. Unions are ‘clothed with power not unlike that of a legislature which is subject to constitutional limitations on its power to deny, restrict, destroy or discriminate against the rights of those for whom it legislates and which is also under an affirmative constitutional duty to protect those rights. [...] Congress has seen fit to clothe the bargaining representatives with powers comparable to those of a legislative body both to create and restrict the rights of those it represents. |
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