386 U.S. 171 (1967) Cited 4,209 times 2 Legal Analyses
Holding that, under the LMRA, an "individual employee has absolute right to have his grievance taken to arbitration regardless of the provisions of the applicable collective bargaining agreement"
495 U.S. 362 (1990) Cited 571 times 1 Legal Analyses
Holding that union could contractually undertake, in collective bargaining agreement, other duties towards member employees in addition to statutorily-imposed duty of fair representation
Holding that the union did not breach its duty of fair representation in negotiating a deal which favored some members of the same bargaining unit over others
In Souter, the plaintiff, who was African-American, sued his labor union for a breach of duty under section 301 of Labor Management Relations Act. He submitted evidence of racially-derisive graffiti on the walls of the automobile plant where he worked and contended that "a racist atmosphere pervaded the [plant] and contributed to hostile attitudes on the part of the union.
Finding bad faith because union concealed from employees a secret oral agreement sacrificing seniority rights while assuring the employees that they would receive these rights
In IUE, the court held that the facts in the case did not make out a breach of the duty of fair representation, as there was no basis in the record to support the NLRB's finding that the Union engaged in bad faith conduct.