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Moore v. International Brotherhood of Electrical Worker, Local 6

Citation: 78 F. App'x 8Docket: No. 02-16485; D.C. No. CV-01-03733-CRB

Court: Court of Appeals for the Ninth Circuit; August 7, 2003; Federal Appellate Court

Narrative Opinion Summary

The appellate court affirmed the district court's summary judgment in favor of the defendants in a case where the plaintiff, representing himself, alleged constitutional violations and breaches under the Labor Management Relations Act (LMRA). The plaintiff's claims under the First and Fifth Amendments were dismissed as the union and its officials were not considered state actors. The court further held that claims of breach of contract and breach of the duty of fair representation under Section 301 of the LMRA could not be pursued against individual union officers, only the union as an entity. State law claims of fraud and intentional infliction of emotional distress were preempted by the LMRA. Additionally, the court found the plaintiff's claims untimely due to a missed six-month statute of limitations. The plaintiff's request for additional discovery was denied as it would not have altered the summary judgment. Ultimately, the court found no merit in the plaintiff's remaining arguments, leading to the affirmation of the district court's decision. The ruling is unpublished and not citable except under specific Ninth Circuit rules.

Legal Issues Addressed

Breach of Contract and Duty of Fair Representation Under LMRA

Application: Claims for breach of contract and breach of duty of fair representation can only be brought against the union as an entity and not against individual officers.

Reasoning: Moore also challenges the dismissal of his claims against individual union officers for breach of contract and breach of duty of fair representation under Section 301 of the Labor Management Relations Act (LMRA).

Constitutional Claims Against Non-State Actors

Application: The court determined that the union and its officials are not state actors, and thus, constitutional claims under the First and Fifth Amendments are not applicable.

Reasoning: Moore claims violations of the First and Fifth Amendments, but the court finds that the union and its officials are not state actors, rendering these constitutional claims non-actionable based on precedent.

Denial of Additional Discovery

Application: The court denied Moore's request for additional discovery, finding it would not aid his claims or affect the summary judgment outcome.

Reasoning: Furthermore, the court denies Moore's request for additional discovery, stating it would not contribute to his claims or prevent summary judgment.

Preemption of State Law Claims by LMRA

Application: State law claims of fraud and intentional infliction of emotional distress are preempted by Section 310 of the LMRA.

Reasoning: Moore's claims of fraud and intentional infliction of emotional distress are deemed preempted by LMRA Section 310 as state law claims.

Statute of Limitations in LMRA Claims

Application: Claims for breach of duty of fair representation and breach of contract are subject to a six-month statute of limitations, which Moore failed to meet.

Reasoning: The court notes that claims for breach of duty of fair representation and breach of contract are subject to a six-month statute of limitations, which Moore missed by filing his complaint over a year after he should have been aware of the alleged breaches.