Robert Yeftich v. Navistar, Inc.
2013 U.S. App. LEXIS 12239
7th Cir.2013Background
- Plaintiffs are union members at Navistar's Indianapolis engine plant represented by UAW Local 98 and 226 under a CBA.
- They allege Navistar laid off workers and did not recall them as work became available, while subcontracting to nonunion plants in violation of the CBA.
- Plaintiffs claim they filed hundreds of grievances with the union and were told grievances were being processed.
- Plaintiffs contend the union diverted, stalled, or abandoned the grievances and misled them about processing status.
- Navistar informed the union in January 2009 of plant closure; by August 2009 the plant closed.
- Plaintiffs sue Navistar under LMRA §301 for breach of the CBA, asserting a prerequisite breach of the union's duty of fair representation; the district court dismissed for failure to state a claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the complaint plausibly states a duty-of-fair-representation claim. | Yeftich asserts the union acted in bad faith/arbitrary by stalling/diverting grievances. | Navistar contends the complaint is conclusory and lacks factual detail. | Yes; the claim is not plausible as pleaded. |
| Whether the complaint provides sufficient factual detail to support bad-faith or arbitrary conduct by the union. | Plaintiffs allege the union knew of CBA violations and misled members. | Allegations are conclusory and lack specifics. | No; the allegations are skeletal and fail to state a plausible claim. |
| Whether the district court properly applied the Twombly/Iqbal plausibility standard. | Plaintiffs argue the facts support a plausible inference of misconduct. | District court correctly required more than conclusory allegations. | Yes; dismissal was proper under Twombly/Iqbal. |
Key Cases Cited
- Vaca v. Sipes, 386 U.S. 171 (1967) (duty of fair representation governed by good-faith, non-arbitrary conduct)
- Thomas v. United Parcel Serv., Inc., 890 F.2d 909 (7th Cir. 1989) (duty to represent employees in grievance process; prerequisites for §301 claim)
- DelCostello v. Int'l Bhd. of Teamsters, 462 U.S. 151 (1983) (hybrid §301 claim requires failure by union or employee to exhaust remedies)
- Neal v. Newspaper Holdings, Inc., 349 F.3d 363 (7th Cir. 2003) (arbitrary, discriminatory, or bad-faith conduct analyzed separately; deference to union discretion)
- Garcia v. Zenith Elecs. Corp., 58 F.3d 1171 (7th Cir. 1995) (minimal investigation required; breadth of union discretion in processing grievances)
- Ooley v. Schwitzer Div., Household Mfg. Inc., 961 F.2d 1293 (7th Cir. 1992) (arbitrary standard is narrow; union actions must be outside a wide range of reasonableness)
- Filippo v. N. Ind. Pub. Serv. Corp., 141 F.3d 744 (7th Cir. 1998) (illustrates deferential standard for union decisions within wide range of reasonableness)
- Twombly v. Bell Atl. Corp., 550 U.S. 544 (2007) (plausibility standard for pleading a claim)