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Adams v. Teamsters Union Local 429

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Adams v. Teamsters Union Local 429
Case number: 21-1372
Status: Closed
Important dates
Filed: Feb. 27, 2019
District court decision:
March 31, 2020
Appeals court decision:
Jan. 20, 2022
Supreme Court decision:
Oct. 3, 2022
District court outcome
The court dismissed the plaintiffs' claims.
Appeals court outcome
The Third Circuit affirmed the district court's ruling.
Supreme Court outcome
Certiorari denied.

This case is one of over a hundred public-sector union lawsuits Ballotpedia tracked following the U.S. Supreme Court's 2018 decision in Janus v. AFSCME. These pages were updated through February 2023 and may not reflect subsequent case developments. For more information about Ballotpedia's coverage of public-sector union policy in the United States, click here. Contact our team to suggest an update.

Adams v. Teamsters Union Local 429 was decided by the U.S. Court of Appeals for the Third Circuit on January 20, 2022. The Third Circuit affirmed the U.S. District Court for the Middle District of Pennsylvania's March 2020 dismissal of the case. The plaintiffs appealed the Third Circuit's ruling to the U.S. Supreme Court on April 20, 2022. The Supreme Court denied review of the case on October 3, 2022.[1][2][3][4][5]

The plaintiffs filed their suit following the Supreme Court's 2018 ruling in Janus v. AFSCME, claiming maintenance of membership requirements and exclusive representation were unconstitutional.[6]

HIGHLIGHTS
  • The parties to the suit: The plaintiffs were Hollie Adams, Jody Weaber, Karen Unger, and Chris Felker. The defendants were Teamsters Union Local 429; Lebanon County, Pennsylvania; Pennsylvania Attorney General Josh Shapiro; and Pennsylvania Labor Relations Board members James M. Darby, Albert Mezzaroba, and Robert H. Shoop.
  • The issue: The plaintiffs claimed that (1) their First Amendment rights had been violated by a requirement to join the union through an unconstitutional scheme and (2) Pennsylvania statutes authorizing unions to operate as exclusive representatives were unconstitutional.
  • The presiding judges: Judge Sylvia Rambo presided over the case in the district court. A three-judge panel—Judges Michael Chagares, David Porter, and Jane Roth—presided over the case in the Third Circuit.
  • The outcome: The Third Circuit affirmed the district court's dismissal of the case. The Supreme Court denied review.

    • Procedural history

    The plaintiffs were Hollie Adams, Jody Weaber, Karen Unger, and Chris Felker. They were represented by attorneys from the Liberty Justice Center. The defendants were Teamsters Union Local 429; Lebanon County, Pennsylvania; Pennsylvania Attorney General Josh Shapiro; and Pennsylvania Labor Relations Board members James M. Darby, Albert Mezzaroba, and Robert H. Shoop. They were represented by attorneys from the Pennsylvania Attorney General's Office; Morcom Law, LLC; and Willig, Williams & Davidson.[4]

    Below is a brief procedural history of the lawsuit:[1][7][2][8][3][4][5]

    • February 27, 2019: The plaintiffs filed their lawsuit on February 27, 2019, in the U.S. District Court for the Middle District of Pennsylvania. The plaintiffs, who were members of the Teamsters Union Local 429, sought to withdraw from the union and cease dues payments following Janus and obtain injunctive and declaratory relief, as well as damages and attorneys’ fees. The plaintiffs claimed that (1) their First Amendment rights had been violated by a requirement to join the union through an unconstitutional scheme and (2) Pennsylvania statutes authorizing unions to operate as exclusive representatives were unconstitutional.[6] After the plaintiffs filed their suit, the union refunded all dues deductions made after the plaintiffs' post-Janus resignation requests by May 20, 2019.[7]
    • May 20, 2019: The defendants filed a motion to dismiss, stating that the plaintiffs’ request for prospective relief no longer applied, as they were no longer union members and dues were no longer being collected. They further stated that claims to damages were barred by the Eleventh Amendment.[9]
    • July 16, 2019: The plaintiffs filed their first motion for summary judgment.
    • July 17, 2019: The plaintiffs filed a brief in support of their first motion for summary judgment.
    • August 13, 2019: The defendants filed reply briefs regarding the motion to dismiss the plaintiffs’ complaints.
    • December 3, 2019: A Report and Recommendation (R&R) submitted by Magistrate Judge Martin C. Carlson recommended that the defendants’ motion to dismiss, which was converted to a motion for summary judgment, be granted.
    • January 13, 2020: The plaintiffs filed a brief in opposition to the R&R and requested their own motion for summary judgment.
    • March 31, 2020: Judge Sylvia Rambo issued an order in favor of the defendants.
    • April 15, 2020: The plaintiffs filed an appeal with the United States Court of Appeals for the Third Circuit.
    • January 20, 2022: The Third Circuit affirmed the district court's ruling.
    • April 20, 2022: The plaintiffs filed a petition for a writ of certiorari to the U.S. Supreme Court.
    • October 3, 2022: The Supreme Court denied review of the case.

    For a list of available case documents, click here.

    Decision

    District court decision

    On March 31, 2020, Judge Sylvia Rambo ordered that the plaintiffs’ claims be dismissed, with prejudice. The Report and Recommendation submitted by Magistrate Judge Martin C. Carlson on December 3, 2019, was adopted, granting the defendants’ motion to dismiss, and the plaintiffs’ subsequent motion for summary judgment was denied. Rambo wrote:[2]

    “ [...] the court finds that Plaintiffs’ arguments do not rely upon law that is binding on this court. Instead, it appears that Plaintiffs are preparing to file an appeal that they hope will result in changes to the law. For example, Plaintiffs effectively ask the court to predict, based on dicta, that the Supreme Court intends to overturn Minnesota State Board for Community Colleges v. Knight, 465 U.S. 271 (1984)—a Supreme Court case that has not been overturned and which explicitly held unions are constitutionally permitted to operate as exclusive representatives—and thus rule that unions are constitutionally barred from operating as the exclusive representative of a group of employees.[10] ”

    Rambo was appointed to the court by President Jimmy Carter (D).

    Appellate court decision

    On January 20, 2022, a three-judge panel—Judges Michael Chagares, David Porter, and Jane Roth—affirmed the district court's dismissal of the case. Roth wrote in the court's opinion:[3]

    “

    On the issue of refund of dues, we have recently held in LaSpina v. SEIU Pennsylvania State Council, that a former union member has 'no standing to seek a refund of any portion of the union dues she made prior to Janus because she cannot tie the payment of those dues to the Union’s unconstitutional deduction of fair-share fees from nonmembers.' LaSpina involved a similar situation to the one we have here: an employee, in an exclusive representation employment situation, who joined the union rather than paying a fair share fee and who then, after Janus, resigned from the union and sued to get a refund of union dues. We dismissed the claim for refund in LaSpina and following LaSpina, we do the same here. The employees lack standing to seek a refund of union dues paid before they resigned the union. The employees’ claims for prospective injunctive and declaratory relief are moot because they have not shown their employers or the union will continue to assess union dues. To the extent Adams and Weaber still seek damages for union dues paid after they resigned the union, their claims are now moot because they have been reimbursed and, in any event, they fail to state a claim under the First Amendment.

    Turning to the claim that the Public Employee Relations Act (PERA), Pennsylvania’s exclusive representation law, violates the First Amendment, we hold that, consistent with every Court of Appeals to consider a post-Janus challenge to an exclusive-representation law, the law does not violate the First Amendment.

    The Supreme Court rejected a First Amendment challenge to an exclusive-representation law in 1984. In Minnesota State Board for Community Colleges v. Knight, a group of teachers challenged a Minnesota law that permitted the designation of an exclusive union representative for school employees. The Court explained that the law did not violate the teachers’ freedoms of speech or association. The state did not 'restrain[] appellees’ freedom to speak on any education-related issue.' Nor did the law impermissibly infringe on 'their freedom to associate or not to associate with whom they please.' And the teachers were 'free to form whatever advocacy groups they like.' ...

    The employees here, like the teachers in Knight, are free to express whatever ideas they wish, including through groups they create and including about the Union. Indeed, PERA protects their right to present certain grievances to their employer. Also like the teachers, the employees are free to associate—or not—with the Union. Given these similarities, this law does not violate the First Amendment.

    The employees’ final argument is that Janus undercut Knight. Janus provides, however, that '[s]tates can keep their labor-relations systems exactly as they are.' Nothing in Janus undermines Knight or exclusive-representation laws.[10]

    		”

    Legal context

    Janus v. AFSCME (2018)

    See also: Janus v. AFSCME

    On June 27, 2018, the Supreme Court of the United States issued a 5-4 decision in Janus v. American Federation of State, County, and Municipal Employees (Janus v. AFSCME), ruling that public-sector unions cannot compel non-member employees to pay fees to cover the costs of non-political union activities.[11]

    This decision overturned precedent established in Abood v. Detroit Board of Education in 1977. In Abood, the high court held that it was not a violation of employees' free-speech and associational rights to require them to pay fees to support union activities from which they benefited (e.g., collective bargaining, contract administration, etc.). These fees were commonly referred to as agency fees or fair-share fees.[11]

    Justice Samuel Alito authored the opinion for the court majority in Janus, joined by Chief Justice John Roberts and Justices Anthony Kennedy, Clarence Thomas, and Neil Gorsuch. Alito wrote, "Abood was poorly reasoned. It has led to practical problems and abuse. It is inconsistent with other First Amendment cases and has been undermined by more recent decisions. Developments since Abood was handed down have shed new light on the issue of agency fees, and no reliance interests on the part of public-sector unions are sufficient to justify the perpetuation of the free speech violations that Abood has countenanced for the past 41 years. Abood is therefore overruled."[11]

    Related litigation

    To view a complete list of the public-sector labor lawsuits Ballotpedia tracked between 2019 and 2023, click here.

    Number of federal lawsuits by circuit

    Between 2019 and 2023, Ballotpedia tracked 191 federal lawsuits related to public-sector labor laws. The chart below depicts the number of suits per federal judicial circuit (i.e., the jurisdictions in which the suits originated).

    Public-sector labor lawsuits on Ballotpedia

    See also: Public-sector union policy in the United States, 2018-2023

    Click show to view a list of cases with links to our in-depth coverage.

    v • e
    Public-sector labor lawsuits
    Federal lawsuits

    Adams v. Teamsters Union Local 429 • Akers v. Maryland State Education Association • Aliser v. SEIU California • Allen v. Ohio Civil Service Employees Association • Allen v. Santa Clara County Correctional • Anderson v. SEIU Local 503 • Babb v. California Teachers Association • Baisley v. International Association of Machinists and Aerospace Workers • Belgau v. Inslee • Bennett v. AFSCME • Bermudez v. SEIU Local 521 • Bierman v. Dayton • Boudreaux v. Louisiana State Bar • Boyle v. SEIU California • Brice v. California Faculty Association • California v. Azar • Campos v. Fresno Deputy Sheriff’s Association • Carey v. Inslee • Casanova v. IAM Local 701 • Chandavong et al. v. Fresno Deputy Sheriff's Association et al. • Cook v. Brown • Cooley v. California Statewide Law Enforcement Association • Crowe v. Oregon State Bar • Cruz v. Union Independiente Autentica de Empleados de la Autoridad de Acueductos y Alcantarillados • Danielson v. Inslee • Diamond v. Pennsylvania State Education Association • Doughty v. State Employees Association of New Hampshire, SEIU, Local 1984 • Durst v. OEA • Few v. United Teachers Los Angeles • File v. Hickey • Fischer v. Murphy • Fisk v. Inslee • Fizer v. Ohio Association of Public School Employees • Fleck v. Wetch • Grega v. Council of New Jersey State College Locals • Grossman v. Hawaii Government Employees Association • Gruber v. Oregon State Bar • Guppy v. City of Los Angeles • Halloran v. AFSCME Council 5 • Hamidi v. SEIU • Hannay v. Kent State • Hartnett v. Penn. State Education Association • Hendrickson v. AFSCME Council 18 • Hernandez v. AFSCME California • Hoekman v. Education Minnesota • Hough v. SEIU Local 521 • Imhoff v. California Teachers Association • Jackson v. Napolitano • James v. SEIU Local 688 • Janus v. AFSCME • Jarchow v. Wisconsin • Kabler v. United Food and Commercial Workers Union, Local 1776 Keystone State • Wenzig v. SEIU Local 668 • Kopie v. International Federation of Professional and Technical Employees • Kurk v. Los Rios Classified Employees Association • Lamberty et al. v. Connecticut State Police Union et al. • LaSpina v. SEIU Pennsylvania State Council • Lee v. Ohio Education Association • Leitch v. AFSCME • Littler v. Ohio Association of Public School Employees • Loescher v. Teamsters Local 320 • Lutter v. JNESO • Mandel v. SEIU Local 73 • Marsh v. AFSCME Local 3299 • Martin v. California Teachers Association • Masuo v. AFSCME AFL-CIO • Matthews v. United Teachers of Los Angeles • Mattos v. AFSCME Council 3 • Mayer v. Wallingford-Swathmore School District • McCain v. Ventura County Federation of College Teachers, AFT Local 1828 • McCollum v. NEA-Alaska • McCutcheon v. CWA Local 7076 • McDonald v. Firth • Mendez v. CTA • Miller v. Inslee • Misja v. PSEA • Molina v. SEIU Local 668 • Mooney v. Illinois Education Association • Nearman v. SEIU Local 503 • Neely v. AFSCME Council 13 • Nguyen v. Admin. and Residual Employees Union • Nichols v. Home Care Providers Union • O'Callaghan v. Drake • Ochoa v. Public Consulting Group • Ocol v. Chicago Teachers Union • Ogle v. Ohio Civil Service Employees Association, AFSCME, Local 11 • Oliver v. SEIU Local 668 • Pellegrino v. New York State United Teachers • Penning v. SEIU Local 1021 • Polk v. Yee • Popp v. ALPAI • Piekarski v. AFSCME Council 5 • Quirarte v. UDW AFSCME Local 3930 • Reisman v. Associated Faculties of the University of Maine • Rizzo-Rupon v. International Association of Machinists and Aerospace Workers, District Lodge 141 • Routh v. Inslee • Schaszberger v. AFSCME Council 13 • Schell v. Oklahoma Supreme Court Justices • Schumaker v. Inslee • Seager v. UTLA • Seidemann v. Professional Staff Congress • Smith v. AFSCME Council No. 8 • Smith v. New Jersey Education Association • Smith v. Bieker • Solomon v. AFSCME District Council 37 • Stroeder v. Service Employees International Union, Local 503 • Sweeney v. Raoul • Sweet v. California Association of Psychiatric Technicians • Taylor v. Heath • Thompson v. AFSCME Council 89, Local 4013 • Thompson v. Marietta Education Association • Thulen v. AFSCME • Uradnik v. Inter Faculty Org. • Utke v. University of Connecticut American Association of University Professors • Weyandt v. PSCOA • Wholean v. CSEA SEIU Local 2001 • Wilford v. National Education Association • Williams v. PSEA • Wolf v. University Professional & Technical Employees • Yates v. Hillsboro Unified School District • Yohn v. California Teachers Association

    See also

    External links

    Case documents

    Supreme Court

    Appeals court

    Trial court

    Footnotes

    1. ↑ 1.0 1.1 PacerMonitor, “Adams et al v. Teamsters Union Local 429 et al,” accessed April 20, 2020
    2. ↑ 2.0 2.1 2.2 PacerMonitor, “Adams v. Teamsters Local Union 429: Order,” March 31, 2020
    3. ↑ 3.0 3.1 3.2 U.S. Court of Appeals for the Third Circuit, "No. 20-1824," January 20, 2022
    4. ↑ 4.0 4.1 4.2 Supreme Court of the United States, "No. 21-1372," accessed May 30, 2022
    5. ↑ 5.0 5.1 Supreme Court of the United States, "Order List: 598 U.S.," October 3, 2022
    6. ↑ 6.0 6.1 PacerMonitor, “Adams v. Teamsters Local Union 429: Complaint,” February 27, 2019
    7. ↑ 7.0 7.1 PacerMonitor, “Adams v. Teamsters Local Union 429: Report and Recommendation,” December 5, 2019
    8. ↑ PacerMonitor, “Hollie Adams, et al v. Teamsters Union Local 429, et al,” accessed April 22, 2020
    9. ↑ PacerMonitor, “Adams v. Teamsters Local Union 429: Motion to Dismiss by Lebanon County,” May 20, 2019
    10. ↑ 10.0 10.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    11. ↑ 11.0 11.1 11.2 Supreme Court of the United States, Janus v. American Federation of State, County, and Municipal Employees, Council 31, et al., June 27, 2018
    v • e
    Public-sector union policy in the United States
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