808 F.3d 734
8th Cir.2015Background
- Plaintiffs are 1A MAT mechanics (the Mechanics), members of Amalgamated Transit Union Local 788, employed by Bi‑State Development Agency (Metro), an interstate compact transit authority receiving federal UMTA funds.
- Mechanics asked Metro’s Board to adopt a framework permitting them to form a separate bargaining unit from the existing Union; the Board took no action.
- Mechanics sued for declaratory relief under §13(c) of the Urban Mass Transportation Act (UMTA), arguing state labor law does not apply to Metro (as an interstate compact) and federal NLRA coverage is inapplicable, leaving no forum to establish a separate unit.
- The Union intervened and moved to dismiss for failure to state a claim, arguing §13(c) does not create a federal private cause of action; Metro did not take a position.
- The district court granted the Union’s motion, concluding Jackson Transit Authority v. Local Division 1285 forecloses a federal private cause of action under §13(c); the Mechanics appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether §13(c) of the UMTA creates a federal private cause of action permitting the Mechanics to obtain a judicially enforceable procedure to form a separate bargaining unit | §13(c) should be enforceable in federal court here because Metro’s interstate‑compact status leaves no applicable state labor law; Jackson Transit Authority is distinguishable | Jackson Transit Authority controls: Congress intended §13(c) protections to be administered via state law and state courts, not as a federal private remedy | Court affirmed dismissal: §13(c) does not create a federal private cause of action; any remedy must come from state law or state courts |
Key Cases Cited
- Jackson Transit Auth. v. Local Div. 1285, Amalgamated Transit Union, AFL‑CIO‑CLC, 457 U.S. 15 (Sup. Ct.) (held §13(c) does not create federal private cause of action; state law/ courts govern transit labor disputes)
- Alexander v. Sandoval, 532 U.S. 275 (Sup. Ct.) (framework for identifying congressional intent to create private rights and remedies)
- Gonzaga Univ. v. Doe, 536 U.S. 273 (Sup. Ct.) (statutory text must display rights‑creating focus to create enforceable individual rights)
- Burke v. Utah Transit Auth., 462 F.3d 1253 (10th Cir.) (held §13(c) does not create a federal private cause of action)
- Cannon v. Univ. of Chicago, 441 U.S. 677 (Sup. Ct.) (discusses rights‑creating statutory language as evidence of intent)
- Blessing v. Freestone, 520 U.S. 329 (Sup. Ct.) (discusses whether statutes create individual rights enforceable in court)
- Zayed v. Associated Bank, N.A., 779 F.3d 727 (8th Cir.) (standard of review for whether a complaint states a claim)
- Miller v. Redwood Toxicology Lab., Inc., 688 F.3d 928 (8th Cir.) (same)