Glacier Northwest, Inc. v. Teamsters
Glacier Northwest, Inc. v. Teamsters | |
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Argued January 10, 2023 Decided June 1, 2023 | |
Full case name | Glacier Northwest, Inc., dba CalPortland v. International Brotherhood of Teamsters Local Union No. 174 |
Docket no. | 21-1449 |
Citations | 598 U.S. __ (more) |
Argument | Oral argument |
Opinion announcement | Opinion announcement |
Case history | |
Prior | Judgment for defendants, [1] (Washington Supreme Court, Dec. 16, 2021); |
Holding | |
The National Labor Relations Act did not preempt Glacier’s state tort claims related to the destruction of company property during a labor dispute where the union failed to take reasonable precautions to avoid foreseeable and imminent danger to the property. Washington Supreme Court reversed and remanded. | |
Court membership | |
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Case opinions | |
Majority | Barrett, joined by Roberts, Sotomayor, Kagan, Kavanaugh |
Concurrence | Thomas (in judgment), joined by Gorsuch |
Concurrence | Alito (in judgment), joined by Thomas, Gorsuch |
Dissent | Jackson |
Laws applied | |
National Labor Relations Act |
Glacier Northwest, Inc. v. International Brotherhood of Teamsters Local Union No. 174, No. 21-1449, 598 U.S. ___ (2023) was a
Background
Glacier Northwest delivers concrete to customers in the State of Washington using ready-mix trucks with rotating drums that prevent the concrete from hardening during transit. Concrete is highly perishable, and even concrete in a rotating drum will eventually harden, causing significant damage to the vehicle. Glacier's truck drivers are members of the International Brotherhood of Teamsters Local Union No. 174. After a collective-bargaining agreement between Glacier and the Union expired, the Union called for a work stoppage on a morning it knew the company was in the midst of mixing substantial amounts of concrete, loading batches into ready-mix trucks, and making deliveries. The Union directed drivers to ignore Glacier's instructions to finish deliveries in progress. At least 16 drivers who had already set out for deliveries returned with fully loaded trucks. By initiating emergency maneuvers to offload the concrete, Glacier prevented significant damage to its trucks, but all the concrete mixed that day hardened and became useless.[2]
Glacier sued the Union for damages in state court, claiming that the Union intentionally destroyed the company's concrete and that this conduct amounted to common-law conversion and trespass to chattels. The Union moved to dismiss Glacier's tort claims on the ground that the National Labor Relations Act preempted them. While a federal law generally preempts state law when the two conflict, the NLRA preempts state law even when the two only arguably conflict. In the Union's view, the NLRA—which protects employees’ rights “to selforganization, to form, join, or assist labor organizations,...and to engage in other concerted activities for the purpose of collective bargaining or other mutual aid or protection”—at least arguably protected the drivers’ conduct, so the State lacked the power to hold the Union accountable for any of the strike's consequences. The Washington Supreme Court agreed with the Union, reasoning that “the NLRA preempts Glacier’s tort claims related to the loss of its concrete product because that loss was incidental to a strike arguably protected by federal law.”[2]
Supreme Court
Amicus briefs
A number of organizations filed amicus briefs, or "friend of the court" filings, in the case when it came before the Supreme Court. Among the organizations that filed amicus briefs in support of the plaintiff, Glacier, were the National Right to Work Legal Defense Foundation, the Landmark Legal Foundation, the United States Chamber of Commerce, and the Buckeye Institute.[3] Amicus briefs in support of the defendant, by contrast, included UNITE HERE International, SMART International, the United Brotherhood of Carpenters and Joiners of America, and the AFL-CIO.[3]
Opinion of the Court
On June 1, 2023, the Supreme Court reversed and remanded the judgment of the Washington Supreme Court in an 8–1 vote, finding that the NLRA does not preempt claims for intentional destruction of property. Justice Amy Coney Barrett wrote the controlling majority opinion, joined by Chief Justice Roberts and Justices Sotomayor, Kagan, and Kavanaugh. The majority found that the union's "actions not only resulted in the destruction of all the concrete Glacier had prepared that day; they also posed a risk of foreseeable, aggravated, and imminent harm to Glacier’s trucks. Because the Union took affirmative steps to endanger Glacier’s property rather than reasonable precautions to mitigate that risk, the NLRA does not arguably protect its conduct," the decision said.[2]
Justice Samuel Alito, joined by Justices Thomas and Gorsuch, concurred in the judgment. Justice Thomas, joined by Justice Gorsuch, also filed an opinion concurring in the judgment. These justices agreed with the majority that the conduct of the union was not protected—but would have resolved the case on broader grounds.
Justice Ketanji Brown Jackson filed the sole dissenting opinion. Jackson argued that the Court "fails, in multiple respects, to heed Congress’s intent with respect to the Board's primary role in adjudicating labor disputes." Jackson also added that the decision will likely create confusion for the lower courts and "risk the erosion of the right to strike."[2][4][5]
Reactions and analysis
There were mixed reactions to the decision. The attorney for the
Some groups praised the decision. The lawyer for the Glacier Northwest, Noel Francisco, argued that the ruling vindicated the principle that
Others were more critical. General president of the International Brotherhood of Teamsters,
References
- ^ "Justices Allow Company to Sue Union for Strike Destruction (2)". news.bloomberglaw.com. Retrieved June 26, 2023.
- ^ a b c d "Glacier Northwest, Inc. v. International Brotherhood of Teamsters, 598 U.S. ___ (2023)". Justia Law. Supreme Court of the United States. Retrieved June 27, 2023. This article incorporates text from this source, which is in the public domain.
- ^ a b "Glacier Northwest, Inc. v. International Brotherhood of Teamsters". SCOTUSblog. Archived from the original on March 18, 2024. Retrieved April 20, 2024.
- ^ Gresko, Jessica (June 1, 2023). "Supreme Court rules against union in labor dispute involving truck drivers and wet concrete". Associated Press. Archived from the original on June 2, 2023.
- ^ Schonfeld, Zach (June 1, 2023). "Ketanji Brown Jackson issues solo dissent in ruling against Teamsters strike". The Hill. Archived from the original on June 8, 2023. Retrieved August 20, 2023.
- ^ Kanu, Hassan (June 7, 2023). "US Supreme Court's ruling in strike case puts unions on defense". Reuters. Archived from the original on June 8, 2023. Retrieved August 20, 2023.
- ^ a b c Hurley, Lawrence (June 1, 2023). "In blow to unions, Supreme Court rules company can pursue strike damage claim". NBC News. Archived from the original on August 19, 2023. Retrieved August 20, 2023.
- ^ a b de Vogue, Ariane; Cole, Devan (June 1, 2023). "Supreme Court sides with cement mixing company over striking workers in latest blow to unions". CNN. Archived from the original on June 20, 2023. Retrieved August 20, 2023.
- ^ a b Savage, David G. (June 1, 2023). "Supreme Court warns unions against strikes that damage an employer's property". Los Angeles Times. Archived from the original on July 26, 2023. Retrieved August 20, 2023.
- ^ McAlevey, Jane (June 1, 2023). "How Should Workers Respond to the Supreme Court's Ruling in "Glacier Northwest"?". The Nation. Archived from the original on June 3, 2023. Retrieved August 20, 2023.
- CATO Institute. Archivedfrom the original on June 3, 2023. Retrieved August 20, 2023.
- ^ Kruzel, John (June 2, 2023). "US Supreme Court hands defeat to organized labor in truckers strike case". Reuters. Archived from the original on July 5, 2023. Retrieved August 20, 2023.
- ^ "O'Brien: SCOTUS Attacks All U.S. Workers" (Press release). Washington, D.C.: International Brotherhood of Teamsters. June 1, 2023. Archived from the original on August 3, 2023. Retrieved August 21, 2023.
- Vice.com. Archivedfrom the original on July 9, 2023. Retrieved August 20, 2023.
- ^ Chemerinsky, Erwin; Fisk, Catherine (June 1, 2023). "Supreme Court ruling erodes the right to strike by empowering employers to sue unions". Los Angeles Times. Archived from the original on June 19, 2023. Retrieved August 20, 2023.
- ^ a b "In a historic step backwards, the US limits the right to strike". Morning Star. Archived from the original on June 6, 2023. Retrieved August 20, 2023.
- ^ Ivanova, Irina (June 2, 2023). "Supreme Court ruling deals another blow to organized labor". CBS News. Archived from the original on June 8, 2023. Retrieved August 20, 2023.
- ^ Luscombe, Richard (June 1, 2023). "US supreme court ruling makes it easier for companies to sue striking workers". The Guardian. Archived from the original on June 20, 2023. Retrieved August 20, 2023.
- UPI. Archivedfrom the original on August 21, 2023. Retrieved August 20, 2023.
- ^ Millhiser, Ian (June 1, 2023). "The Supreme Court deals another blow to labor unions". Vox. Archived from the original on June 22, 2023. Retrieved August 20, 2023.
- ^ Kanu, Hassan (October 20, 2022). "U.S. Supreme Court poised to give companies new power to sue over strikes". Reuters. Archived from the original on March 22, 2023. Retrieved August 20, 2023.
- ^ McAlevey, Jane (July 28, 2023). "The Teamsters' Proposed Agreement With UPS Is a Great Victory by and for the Workers". The Nation. Archived from the original on August 13, 2023. Retrieved August 20, 2023.