Brandon Chapman v. United Auto Workers Local 1005
2012 U.S. App. LEXIS 4159
| 6th Cir. | 2012Background
- Chapman sued GM for breach of the collective bargaining agreement and the UAW for breach of the duty of fair representation in a hybrid § 301/fair representation suit.
- Chapman did not exhaust internal UAW remedies or pursue the UAW appeals process before filing suit.
- GM and the UAW moved for summary judgment; the district court held Chapman barred by failure to exhaust.
- Chapman argued Molpus required remand for trial to determine whether exhaustion could be excused.
- The case was reheard en banc to address whether Molpus overruled by Clayton-based exhaustion analysis.
- The court overruled portions of Molpus and Burkholder, affirmed summary judgment for GM and UAW.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether exhaustion of internal union remedies can be excused in a hybrid § 301/fair representation suit | Chapman argues Molpus requires remand for trial on excusing exhaustion. | Clayton framework controls; exhaustion not excused absent the three factors. | Exhaustion not excused; failure to exhaust internal remedies bars suit. |
| Whether the three Clayton factors support excusing failure to exhaust internal union remedies | Molpus exemptions apply to excuse exhaustion in fair representation claims. | No hostile union officials, inadequate remedies, or undue delay shown. | No factor supports excusing exhaustion; Chapman’s claim barred. |
| Whether internal union procedures could have reactivated Chapman’s grievance | Internal appeals could have remedied or reactivated the grievance. | Procedures would be adequate but not applicable because Chapman didn’t pursue them. | Internal procedures were adequate to reactivate the grievance; failure to exhaust remains unexcused. |
Key Cases Cited
- Clayton v. International Union, 451 U.S. 679 (U.S. 1981) (distinguishes internal union remedies from contractual procedures; three-factor excusal test)
- Republic Steel Corp. v. Maddox, 379 U.S. 650 (U.S. 1965) (exhaustion of contractual grievance procedures required)
- Vaca v. Sipes, 386 U.S. 171 (U.S. 1967) (union duty of fair representation; exhaustion limits)
- Hines v. Anchor Motor Freight, Inc., 424 U.S. 554 (U.S. 1976) (exemption from exhaustion when union breaches duty)
- DelCostello v. Int’l Bhd. of Teamsters, 462 U.S. 151 (U.S. 1983) (hybrid § 301/fair representation interdependence matters)
- Molpus, 171 F.3d 360 (6th Cir. 1999) (anomalous exhaustion approach later overruled in part)
- Burkholder v. Int’l Union, 299 F. App’x 531 (6th Cir. 2008) (concurrence criticized Molpus; exhaustion doctrine clarified)
- Willetts v. Ford Motor Co., 583 F.2d 852 (6th Cir. 1978) (separate prerequisites for exhaustion of union remedies and contractual remedies)