Lane v. 1199 SEIU Healthcare Workers Labor Union
694 F. App'x 819
2d Cir.2017Background
- Lane, a registered nurse, sued Montefiore Wakefield Hospital and the 1199 SEIU Union after her termination; she later voluntarily dismissed claims against Montefiore.
- Remaining claims against the Union included state-law wage-theft and constructive dismissal claims, which Lane does not contest were dismissed.
- District court treated the complaint liberally as asserting a hybrid Section 301/LRMA claim (employer breach + union breach of duty of fair representation) and dismissed under Rule 12(b)(6).
- The district court found Lane failed to allege sufficient facts showing the Union acted arbitrarily, discriminatorily, or in bad faith, or that any such conduct caused her injuries.
- The district court sua sponte offered Lane leave to amend, but she declined and never moved to amend; the court dismissed the complaint with prejudice.
- On appeal, this Court affirmed, concluding Lane could not plead a viable hybrid claim, that Section 301 preempts contract claims dependent on a CBA, and that amendment would have been futile given the record allegations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether complaint plausibly states a hybrid §301/Duty of Fair Representation (DFR) claim | Lane argued her allegations could support a hybrid claim against the Union for failing to represent her | Union argued Lane failed to plead facts showing arbitrary, discriminatory, or bad-faith conduct causally connected to her injury | Court held Lane failed to plead the requisite facts for a DFR breach and affirmed dismissal |
| Whether Section 301 preempts a standalone breach-of-contract claim against the Union | Lane contended facts could support a breach-of-contract claim against the Union | Union asserted Section 301 preempts claims substantially dependent on collective-bargaining analysis | Court held Section 301 preempts such contract claims and those are not available here |
| Whether district court erred by dismissing with prejudice without granting leave to amend | Lane argued dismissal with prejudice was improper because other claims were possible | Union noted the court had offered leave and Lane did not seek amendment; factual additions would not cure defects | Court held no error: leave to amend was offered; Lane did not request it; amendment would have been futile |
| Whether additional facts alleged on appeal (age, race, dues payments, positive evaluations) cure pleading defects | Lane argued these facts suggest discriminatory motive and causation | Union argued those facts do not tie race/age to Union conduct or show DFR breach causation | Court held those facts do not plausibly connect Union’s conduct to discrimination or DFR breach; dismissal stands |
Key Cases Cited
- Trustees of Upstate N.Y. Eng’rs Pension Fund v. Ivy Asset Mgmt., 843 F.3d 561 (2d Cir. 2016) (standard of review for Rule 12(b)(6) dismissal)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for pleadings)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (court need not accept legal conclusions)
- Domnister v. Exclusive Ambulette, Inc., 607 F.3d 84 (2d Cir. 2010) (elements of hybrid §301/DFR claim)
- Vaughn v. Air Line Pilots Ass’n, Int’l, 604 F.3d 703 (2d Cir. 2010) (DFR requires arbitrary, discriminatory, or bad-faith conduct causally connected to injury)
- Franchise Tax Bd. v. Constr. Laborers Vacation Tr. for S. Cal., 463 U.S. 1 (1983) (Section 301 preemption of state-law claims dependent on CBA analysis)
- Caterpillar, Inc. v. Williams, 482 U.S. 386 (1987) (state-law claims preempted when resolution depends on interpretation of collective-bargaining agreement)
- Gallop v. Cheney, 642 F.3d 364 (2d Cir. 2011) (district court not required to grant leave to amend when plaintiff does not request it and amendment would be futile)