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Enright v. Local Lodge 389 International Ass'n of Machinists

Citation: 46 F. App'x 499Docket: No. 01-56915; D.C. No. CV-00-01888-NAJ(LSP)

Court: Court of Appeals for the Ninth Circuit; September 17, 2002; Federal Appellate Court

Narrative Opinion Summary

In this case, the appellant challenged the district court's dismissal of his claims against the International Association of Machinists, Aerospace Workers (IAMAW) and the summary judgment in favor of Local Lodge 389. The claims involved allegations of breach of the duty of fair representation, violations of the Americans with Disabilities Act (ADA), and retaliation. The appellate court, exercising jurisdiction under 28 U.S.C. 1291, conducted a de novo review and affirmed the lower court's decisions. The court upheld the dismissal against IAMAW, as the appellant failed to demonstrate IAMAW's participation in the alleged misconduct or that Local Lodge 389 acted as its agent. Furthermore, the summary judgment in favor of Local Lodge 389 was affirmed, with the court finding no material fact as to whether the lodge's actions were arbitrary, discriminatory, or in bad faith. The ADA claims were dismissed due to a lack of evidence linking adverse employment actions to the appellant's disability, and no retaliatory threats were substantiated. The appellant's procedural due process claim regarding the denial of oral argument was also dismissed for failure to show prejudice. The court's decision to consider the arbitrator's findings further solidified the outcome, leading to an affirmation of the rulings, which are not designated for publication under Ninth Circuit Rule 36-3.

Legal Issues Addressed

Agency in Union Representation

Application: The court found that the International Association of Machinists, Aerospace Workers was not liable as the plaintiff did not establish that Local Lodge 389 acted as its agent.

Reasoning: The district court correctly dismissed the claims against IAMAW because Enright did not demonstrate that IAMAW participated in the actions related to his claims or that Local Lodge 389 acted as its agent.

Americans with Disabilities Act (ADA) Claims

Application: The court dismissed the ADA claims as the plaintiff failed to show that Local Lodge 389's actions led to adverse employment actions or retaliatory threats due to his disability.

Reasoning: Enright's ADA claims were dismissed because he failed to present evidence that Local Lodge 389's actions resulted in adverse employment actions due to his disability, nor did he provide evidence of retaliatory threats.

Consideration of Arbitrator's Decision

Application: The court did not err in considering the arbitrator's decision, implying its relevance and permissibility in the proceedings.

Reasoning: Additionally, the court did not err in considering the arbitrator's decision.

Duty of Fair Representation

Application: The court upheld summary judgment for Local Lodge 389, determining no evidence of arbitrary, discriminatory, or bad-faith conduct in the union's handling of grievances.

Reasoning: The court also affirmed summary judgment on the breach of fair representation claim against Local Lodge 389, finding no genuine issue of material fact regarding whether the lodge's conduct was arbitrary, discriminatory, or in bad faith.

Jurisdiction and Standard of Review

Application: The court of appeals reviews the district court's decisions de novo, affirming the lower court's dismissal and summary judgment.

Reasoning: The court has jurisdiction under 28 U.S.C. 1291 and reviews the matter de novo, affirming the lower court's decisions.

Procedural Due Process in Summary Judgment

Application: The court rejected the plaintiff's assertion regarding the denial of oral argument, noting no demonstrated prejudice from the lack of oral proceedings.

Reasoning: His argument regarding the denial of oral argument before summary judgment was rejected as he could not prove prejudice.