Sylla v. Amazon Labor Union
1:23-cv-05261
E.D.N.YMay 9, 2024Background
- A group of Amazon Labor Union (ALU) members (the "reform caucus") sued the union and its president, Chris Smalls, for violating the Labor Management Relations Act by postponing mandated leadership elections.
- The NLRB certified the ALU in January 2023, representing employees at Amazon's JFK8 fulfillment center.
- Dispute centered around a revised ALU constitution that delayed officer elections until after ratifying a bargaining agreement, contrary to prior constitutional requirements for prompt elections after certification.
- After settlement negotiations, the parties agreed in January 2024 to a Consent Order establishing a process for membership votes on leadership elections.
- After the Consent Order was entered and implemented, four pro se members sought to intervene, claiming exclusion from settlement decisions and expressing various concerns about union governance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timeliness of Motions to Intervene | Motions untimely; settled order should stand | Initially opposed as untimely and without basis | Intervention denied; motions filed too late after Consent Order |
| Interest Impaired by Consent Order | Movants' interests not at stake, or are protected by settlement | Consent Order drafted considering interests | No impaired interest; objections concern internal union governance |
| Consent Order vs. Union Constitution | Order properly negotiated, binding regardless of bylaw conflict | Argued potential conflict with ALU constitution | Consent Order controls; conflicting bylaws are inoperative (binding) |
| Permissive Intervention | Would delay and prejudice parties; no common claim/defense | Defendants later suggested re-negotiation needed | Denied; no timely or valid basis and would disrupt settlement |
Key Cases Cited
- United States v. Int’l Bhd. of Teamsters, Chauffeurs, Warehousemen & Helpers of Am., AFL-CIO, 931 F.2d 177 (2d Cir. 1991) (consent decrees can supersede conflicting union bylaws during their implementation)
- Rufo v. Inmates of the Suffolk Cnty. Jail, 502 U.S. 367 (1992) (modification of consent decrees requires significant change in fact or law)
- Butler, Fitzgerald & Potter v. Sequa Corp., 250 F.3d 171 (2d Cir. 2001) (timeliness is crucial for intervention motions)
- Catanzano v. Wing, 103 F.3d 223 (2d Cir. 1996) (assessment of timeliness factors for intervention motions)
- Juan F. By & Through Lynch v. Weicker, 37 F.3d 874 (2d Cir. 1994) (modification or vacatur of a consent order is a high burden)