Murray v. Amalgamated Transit Union
220 F. Supp. 3d 72
| D.D.C. | 2016Background
- Janice Murray and Alnett (Tim) Queen won Local 1300’s June 2013 officer elections (President and Vice‑President); a challenger (McClure) contested their eligibility for not being members in good standing.
- While McClure’s challenge was pending, Murray was denied seating as an ATU Convention delegate because Local 1300’s ballots lacked the words “and Convention Delegate” required by ATU §6.7.
- The ATU later invalidated the June 2013 election, removed Murray and Queen from office, and McClure won a re‑run; Murray and Queen sued under Title I of the LMRDA and for breach of the ATU Constitution.
- After extensive litigation, the Court sua sponte raised whether Title IV’s exclusivity divested it of jurisdiction; in Murray IV the Court dismissed the case for lack of subject‑matter jurisdiction, concluding Title IV covered the challenged election.
- Plaintiffs moved under Rule 59(e) to alter or amend the judgment, arguing (1) manifest injustice, (2) Title IV did not apply to the Local 1300 election (relying on ATU constitutional language and a DOL letter), and (3) Queen’s claim is distinct from Murray’s.
- The Court granted reconsideration in part: it reaffirmed that the Local 1300 election fell under Title IV as an election of ex officio delegates, rejected the new‑evidence claim, but reversed its prior conclusion as to Queen — permitting Queen’s Title I claim to proceed because his office (Vice‑President) was not an ex officio delegate position.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether dismissal causes manifest injustice | Dismissal after two years and late‑raised jurisdictional issue is unfair | Courts may raise subject‑matter jurisdiction at any time; no injustice | No manifest injustice; dismissal timing does not bar sua sponte jurisdictional review |
| Whether the Local 1300 election was a Title IV‑covered election of ex officio delegates | §6.7 requires the ballot “Delegate Phrase”; absence means not a delegates election | §6.7 allows local to provide for ex officio delegates; the ballot notice is a procedural requirement, not a prerequisite | Title IV applies; election was for ex officio delegates despite missing ballot language |
| Whether new evidence (DOL letter) shows Title IV inapplicable | DOL officials told plaintiffs DOL lacked jurisdiction; Wheeler letter confirms no DOL remedy for Local 1300 election | ATU: letter is not new/evidence and is inconsistent with DOL regulations | Evidence is not newly discovered or persuasive; does not warrant reconsideration |
| Whether Queen’s Title I claim is barred by Title IV exclusivity if Murray’s is | Plaintiffs: Queen’s claim may be distinct because Vice‑President is not an ex officio delegate | ATU: Title IV applies to the election as a whole and thus bars both plaintiffs’ claims | Court reversed earlier view; Queen’s Title I claim is not barred because Title IV does not cover the Vice‑President position |
Key Cases Cited
- Local No. 82, Furniture & Piano Moving v. Crowley, 467 U.S. 526 (LMRDA Title I vs Title IV relationship and exclusivity)
- Wildberger v. American Federation of Government Employees, AFL‑CIO, 86 F.3d 1188 (D.C. Cir.) (Title I protection for members of government‑only locals vis‑à‑vis mixed parent)
- Knisley v. Teamsters Local 654, 844 F.2d 387 (6th Cir.) (Secretary may order remedies only for positions covered by Title IV; exclusivity inapplicable to noncovered offices)
- Theodus v. McLaughlin, 852 F.2d 1380 (D.C. Cir.) (context on DOL rulemaking about ex officio delegates)
- Ruhrgas AG v. Marathon Oil Co., 526 U.S. 574 (courts must police subject‑matter jurisdiction sua sponte)