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Casanova v. IAM Local 701

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Casanova v. IAM Local 701
Case number: 20-20
Status: Closed
Important dates
Filed: Jan. 22, 2019
District court decision:
Sept. 11, 2019
Appeals court decision:
Feb. 11, 2020
Supreme Court decision:
Jan. 25, 2021
District court outcome
Public-sector unions cannot be required to refund agency fees paid prior to Janus v. AFSCME.
Appeals court outcome
Affirmed district court’s decision
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.

Casanova v. IAM Local 701 was decided by a three-judge panel of the U.S. Court of Appeals for the Seventh Circuit on February 11, 2020. The appellate panel granted the motion for summary affirmance in the appeal, upholding the decision of the U.S. District Court for the Northern District of Illinois, which had held that public-sector unions cannot be required to refund agency fees paid prior to the U.S. Supreme Court's 2018 ruling in Janus v. AFSCME. In Janus, the high court held that public-sector unions cannot require non-members to pay fees to support unions' non-political activities. The Supreme Court denied the plaintiff's petition to review the case on January 25, 2021.[1][2][3][4][5]

HIGHLIGHTS
  • The parties to the suit: The plaintiff was Benito Casanova. The defendant was the International Association of Machinists, Local 701.
  • The issue: Can public-sector unions be held liable for refunding agency fees paid prior to the Supreme Court's ruling in Janus v. AFSCME, which held that such fees are unconstitutional?
  • The presiding judges: A three-judge panel of the U.S. Court of Appeals for the Seventh Circuit considered the case. The panel was comprised of Judges Kenneth Ripple, David Hamilton, and Amy Barrett. Judge Ripple was appointed by President Ronald Reagan (R), Judge Hamilton by President Barack Obama (D), and Judge Barrett by President Donald Trump (R).
  • The outcome: The appellate panel granted a summary motion for affirmance, upholding that the union had acted in good faith and in accordance with the law when it collected agency fees and, therefore, could not be held liable for refunding these fees.

    • Procedural history

    The plaintiff was Benito Casanova, represented by counsel from the National Right to Work Legal Defense Foundation. The defendant was the International Association of Machinists, Local 701, represented by counsel from Bredhoff & Kaiser PLLC.

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

    • January 22, 2019: The plaintiff in Casanova v. IAM Local 701 first filed his lawsuit on January 22, 2019, in the U.S. District Court for the Northern District of Illinois. The plaintiff filed an initial complaint following Janus v. AFSCME that included challenges to the constitutionality of union membership requirements and fee collection, as well as requests for a refund of all agency fees, costs, and attorney’s fees.
    • September 11, 2019: The district court issued an order dismissing the plaintiff’s claim and terminating the lawsuit.
    • October 9, 2019: An appeal was docketed with the U.S. Court of Appeals for the Seventh Circuit.
    • February 11, 2020: The appellate court granted the motion for summary affirmance based on decisions made in Janus v. AFSCME and Mooney v. Illinois Education Association, and terminated the lawsuit.
    • July 9, 2020: The plaintiff appealed to the U.S. Supreme Court.
    • January 25, 2021: The Supreme Court denied review of the case.

    For a list of available case documents, click here.


    Decision

    District court decision

    On September 11, 2019, Judge Sharon Johnson Coleman issued an order in favor of the defendant, granting the union’s motion to dismiss based on a good-faith defense. Coleman wrote the following in the court's docket notification regarding the order:[4]

    “ Local 701 contends that the good-faith defense to Section 1983 liability disposes of the claim as a matter of law. Every court that has considered this issue has uniformly held that a plaintiff cannot collect damages for fair-share fees collected by a union before the change in Supreme Court precedent where a defendant establishes good-faith reliance as a matter of law. See, e.g., Janus v. AFSCME Council 31, No. 15 C 1235, 2019 WL 1239780 (N.D. Ill. Mar. 18, 2019) (Gettleman, J.); Danielson v. AFSCME Council 28, 340 F. Supp. 3d 1083 (W.D. Wash. 2018); Lee v. Ohio Educ. Ass'n, 366 F. Supp. 3d 980 (N.D. Ohio 2019). Casanova, however, did not address the cases that had been decided by the date he filed his opposition brief nor did he seek leave of Court to respond to any of the various notices of supplemental authority that Local 701 filed with the Court. The Court finds these cases, which include many decided at the motion to dismiss juncture, factually indistinguishable and persuasive. Casanova alleges Local 701 collected fees in accordance with Illinois's laws. Casanova further alleges Local 701 ceased collecting the fees once the Supreme Court decided Janus. Thus, the Court agrees that Local 701 satisfied the good-faith defense and declines to open discovery into the matter. The Court grants Local 701's motion12 and dismisses Casanova's complaint with prejudice.[7] ”
    —Judge Coleman

    Coleman was appointed by President Barack Obama (D).

    Appellate court decision

    On February 11, 2020, a three-judge panel issued an order granting the motion for summary affirmance in the appeal. The panel wrote the following in the court's order:[8]

    “

    IT IS ORDERED that the motion is GRANTED. The judgment is summarily AFFIRMED pursuant to Janus v. AFSCME, 942 F.3d 352 (7th Cir. 2019), and Mooney v. Ill. Educ. Ass'n, 942 F.3d 368 (7th Cir. 2019).

    [7]

    		”
    —Judges Ripple, Hamilton, and Barrett

    Judges Kenneth Ripple, David Hamilton, and Amy Barrett were appointed by President Ronald Reagan (R), President Barack Obama (D), and President Donald Trump (R), respectively.

    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.[9]

    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.[9]

    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."[9]

    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, “Casanova v. International Association of Machinists, Local 701,” accessed May 7, 2020
    2. ↑ 2.0 2.1 PacerMonitor, “Benito Casanova v. International Association of M,” accessed May 7, 2020
    3. ↑ 3.0 3.1 Court Listener, “Casanova v. IAM Local 701: Class Action Complaint,” January 22, 2019
    4. ↑ 4.0 4.1 4.2 Court Listener, “Casanova v. IAM Local 701: Notification of Docket Entry,” September 11, 2019
    5. ↑ 5.0 5.1 Supreme Court of the United States, "Order List: 592 U.S.," January 25, 2021
    6. ↑ Supreme Court of the United States, "Petition for Writ of Certiorari," July 9, 2020
    7. ↑ 7.0 7.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    8. ↑ PacerMonitor, “Order,” February 11, 2020
    9. ↑ 9.0 9.1 9.2 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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