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Baisley v. International Association of Machinists and Aerospace Workers

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Baisley v. International Association of Machinists and Aerospace Workers
Case number: 20-1643
Status: Closed
Important dates
Filed: May 16, 2019
District court decision:
March 19, 2020
Appeals court decision:
Dec. 22, 2020
Supreme Court decision
Oct. 4, 2021
District court outcome
Judge Lee Yeakel dismissed the plaintiff's complaint.
Appeals court outcome
A three-judge panel of the Fifth Circuit affirmed Yeakel'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.

Baisley v. International Association of Machinists and Aerospace Workers was decided by the U.S. Court of Appeals for the Fifth Circuit on December 22, 2020. Following the U.S. Supreme Court's 2018 ruling in Janus v. AFSCME, the plaintiff filed a complaint challenging the constitutionality of the International Association of Machinists and Aerospace Workers (IAM) requiring non-union members to opt out of paying union dues. The Fifth Circuit affirmed the U.S. District Court for the Western District of Texas's March 2020 dismissal of the suit. The Supreme Court denied review of the case on October 4, 2021.[1][2][3][4][5]

HIGHLIGHTS
  • The parties to the suit: The plaintiff was Arthur Baisley, an employee of United Airlines. The defendant was the International Association of Machinists and Aerospace Workers (IAM).
  • The issue: Is the requirement for non-union members to opt out of paying union dues constitutional?
  • The presiding judges: Judge Lee Yeakel presided over the district court proceedings. A three-judge appellate panel included Fifth Circuit Judges Edith Clement, James Ho, and Stuart Kyle Duncan.
  • The outcome: The U.S. Court of Appeals for the Fifth Circuit affirmed the U.S. District Court for the Western District of Texas's dismissal of the suit. The Supreme Court denied review.

    • Procedural history

    The plaintiff was Arthur Baisley. He was represented by attorneys from Jenkins & Watkins, P.C. and the National Right to Work Legal Defense Foundation. The defendant was the International Association of Machinists and Aerospace Workers. The defendant was represented by attorneys from Deats Durst & Owen, PLLC and Guerrieri, Bartos & Roma, PC.

    Below is a brief procedural history of the lawsuit:[2][3][4][1][6][5]

    • May 16, 2019: The plaintiff filed his complaint in the U.S. District Court for the Western District of Texas (case number 1:19-cv-00531). The complaint challenged the constitutionality of the union’s opt-out requirements and requested that the union be enjoined from enforcing those requirements and that compensatory and nominal damages be awarded.
    • September 13, 2019: A hearing was held regarding the defendant’s motion to dismiss for failure to state a claim.
    • March 19, 2020: The district court granted the defendant’s motion to dismiss for failure to state a claim.
    • April 17, 2020: The plaintiff filed an appeal in the U.S. Court of Appeals for the Fifth Circuit.
    • December 22, 2020: The Fifth Circuit affirmed the district court's ruling.
    • May 21, 2021: The plaintiff filed a writ of certiorari to the U.S. Supreme Court.
    • October 4, 2021: The Supreme Court denied review of the case.

    For a list of available case documents, click here.

    Decision

    District court decision

    On March 19, 2020, Judge Lee Yeakel granted the defendant’s motion to dismiss for failure to state a claim.[2]

    Yeakel was appointed by President George W. Bush (R).

    Appellate Court Decision

    On December 22, 2020, a three-judge panel of the U.S. Court of Appeals for the Fifth Circuit—Judges Edith Clement, James Ho, and Stuart Kyle Duncan—affirmed the district court's ruling. Clement wrote:[1]

    “

    "... we are reminded of the Supreme Court’s caution: "If a precedent of this Court has direct application in a case, yet appears to rest on reasons rejected in some other line of decisions, the Court of Appeals should follow the case which directly controls, leaving to this Court the prerogative of overruling its own decisions." ... Heeding that advice, we find no constitutional infirmity in the IAM’s opt-out procedures under the settled decisions of the Supreme Court and this Circuit. By extension, Baisley’s constitutional-avoidance statutory and Duty of Fair Representation claims also fail. [7]

    		”

    Clement was appointed to the court by President George W. Bush (R). Ho and Duncan were appointed by President Donald Trump (R).

    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.[8]

    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.[8]

    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."[8]

    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 1.2 Justia, "Baisley v. International Association of Machinists and Aerospace Workers, No. 20-50319 (5th Cir. 2020)," December 22, 2020
    2. ↑ 2.0 2.1 2.2 PacerMonitor, “Baisley v. International Association of Machinists and Aerospace Workers,” accessed May 2, 2020 Cite error: Invalid <ref> tag; name "pacermonitor" defined multiple times with different content
    3. ↑ 3.0 3.1 PacerMonitor, “Arthur Baisley v. IAM,” accessed May 2, 2020 Cite error: Invalid <ref> tag; name "pacerappeal" defined multiple times with different content
    4. ↑ 4.0 4.1 PacerMonitor, “Baisley v. International Association of Machinists and Aerospace Workers: Complaint,” May 16, 2019 Cite error: Invalid <ref> tag; name "complaint" defined multiple times with different content
    5. ↑ 5.0 5.1 Supreme Court of the United States, "20-1643," accessed October 5, 2021
    6. ↑ Supreme Court of the United States, "Petition for Writ of Certiorari," May 21, 2021
    7. ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    8. ↑ 8.0 8.1 8.2 Supreme Court of the United States, Janus v. American Federation of State, County, and Municipal Employees, Council 31, et al., June 27, 2018
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