Couch v. Sheet Metal Workers International Association, 4:14-cv-00601

Michael Couch was Local 270's business manager (2006–Apr 2010), then became an SMWIA organizer while retaining Local 270 membership.
In Jan 2012 Local 270's business manager David Johnson filed charges accusing Couch of improper accounting (2006–2009); Couch alleges the charges were retaliatory based on prior political conflict and criticism.
SMWIA convened a trial board (Feb 8–9, 2012) that fined Couch $76,408; Couch appealed to SMWIA's General Executive Council (GEC), which on Mar 21, 2013 reduced the fine to $46,758.
Couch exhausted internal union remedies and filed this suit on Mar 13, 2014 asserting: (1) LMRDA procedural violations, (2) LMRDA retaliation for free speech, and (3) LMRA breach of labor agreement.
Defendants moved to dismiss: arguing statute of limitations bars claims, plaintiff failed to join/raise claims in a pending state action, and that Couch's misdemeanor conviction bars equitable relief (unclean hands).
Court transferred venue to N.D. Okla., considered Rule 12(b)(6) motion, and denied dismissal: finding LMRDA and LMRA claims timely (tolling while internal appeals pending), no res judicata basis shown, and declining to dismiss equitable relief on unclean hands at pleading stage.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Timeliness of LMRDA claims	Tolling while exhausting union remedies; final SMWIA decision Mar 21, 2013 so suit filed within limitations	Claims occurred 2010–2012 so suit (Mar 13, 2014) is time-barred	LMRDA claims timely — statute tolled during internal exhaustion (citing precedent)
Timeliness of LMRA claim	Claim is a straight breach of contract; 5-year Oklahoma statute applies; timely filed	Claim governed by 6-month hybrid / DFR limitation and is untimely	LMRA claim characterized as breach of contract, governed by 5-year Oklahoma limitation; timely filed
Preclusion / failure to join state action	Not addressed as bars; no final state-court judgment shown	Claims barred because plaintiff failed to join/raise them in pending state suit	Not barred — defendants did not show a final judgment or res judicata basis to preclude federal suit
Unclean hands / equitable relief	Conviction insufficient at pleading stage to bar equitable relief; discovery and credibility issues belong to later stages	Couch's misdemeanor conviction and conduct should preclude equitable relief now	Denied — court will not resolve unclean hands at motion to dismiss; credibility can be addressed later through discovery/jury argument

Reed v. United Transp. Union, 488 U.S. 319 (LMRDA claims governed by forum's personal-injury statute of limitations)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (pleading standard requires plausible claims)
Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard and treatment of conclusory allegations)
DelCostello v. Int’l Broth. of Teamsters, 462 U.S. 151 (hybrid LMRA/DFR claims and statute of limitations)
Edwards v. Int’l Union, United Plant Guard Workers of Am., 46 F.3d 1047 (10th Cir.) (six-month DFR limitation described)
Cantrell v. Int’l Bhd. of Elec. Workers, Local 2021, 32 F.3d 465 (10th Cir.) (Oklahoma two-year rule for personal injury applied to LMRDA claims)
Volkman v. United Transp. Union, 73 F.3d 1047 (10th Cir.) (tolling while exhausting internal union remedies)
Wall v. Constr. & Gen. Laborers’ Union, Local 230, 224 F.3d 168 (2d Cir.) (tolling during internal remedies)
B. Willis, C.P.A., Inc. v. BNSF Ry. Corp., 531 F.3d 1282 (10th Cir.) (res judicata principles when final judgment exists)