Reid v. United Brotherhood of Teamsters North Atlantic District Local 804
1:16-cv-08021
S.D.N.Y.Jun 16, 2017Background
- Plaintiff Mark A. Reid, an African-American of Jamaican descent, was discharged by UPS on or about April 30, 2014; he was represented by Teamsters Local 804 and union rep Christopher Sabatino.
- A grievance was filed under the collective bargaining agreement (CBA); Plaintiff requested the Union demand arbitration but the Union did not do so within the CBA’s 33 working-day window.
- Reid alleges the Union’s failure to demand arbitration was discriminatory under the New York State Human Rights Law (NYSHRL) based on race and ethnic origin.
- The Union removed the case to federal court asserting complete preemption by the federal duty of fair representation; Plaintiff moved to remand to state court.
- The district court treated the NYSHRL claim as preempted by the federal duty of fair representation, applied the six-month statute of limitations governing such federal claims, and found Reid’s suit (filed more than two years after discharge) time-barred.
- The court denied remand, granted the Union’s motion for judgment on the pleadings, and dismissed the complaint against both defendants.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the NYSHRL claim is completely preempted by the federal duty of fair representation | Reid frames the claim solely as a state-law discrimination claim under NYSHRL | The duty of fair representation arising under federal labor law completely preempts state claims that duplicate duties owed under that federal duty | Court: NYSHRL claim is completely preempted when it duplicates the federal duty of fair representation |
| Whether removal to federal court was proper | Reid argued for remand to state court | Union argued removal proper because federal law completely preempts the pleaded state claim | Court: Removal proper; remand denied |
| Applicable statute of limitations after preemption | Reid proceeded under state law timeline implicitly | Union argued federal 6-month limitations period for duty of fair representation claims applies | Court: Six-month federal limitations period applies |
| Timeliness of the action | Reid filed suit August 24, 2016, asserting NYSHRL claims | Union argued the claim accrued when the Union's refusal to demand arbitration became final (within 33 working days), so the suit was untimely | Court: Claim accrued in 2014; suit filed after six-month period and is time-barred; complaint dismissed |
Key Cases Cited
- Vaca v. Sipes, 386 U.S. 171 (establishes the federal duty of fair representation)
- Caterpillar Inc. v. Williams, 482 U.S. 386 (well-pleaded complaint rule and complete preemption doctrine)
- Marcus v. AT&T Corp., 138 F.3d 46 (2d Cir.) (discussion of federal-question jurisdiction and preemption principles)
- DelCostello v. Int’l Bhd. of Teamsters, 462 U.S. 151 (six-month statute of limitations for hybrid § 301/duty of fair representation claims)
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard for plausibility under Rule 12)