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Imhoff v. California Teachers Association

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Imhoff v. California Teachers Association
Case number: 0:19-cv-55868
Status: Terminated
Important dates
Filed: November 7, 2018
District court decision: July 1, 2019
Appeals court decision: October 1, 2019
District court outcome
The court ruled in favor of the defendants and dismissed the suit.
Appeals court outcome
The plaintiffs voluntarily dismissed the appeal.

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.

Imhoff v. California Teachers Association was dismissed on October 1, 2019, from the U.S. Court of Appeals for the Ninth Circuit. The plaintiffs sought refunds for fees paid to third-party charities in lieu of fair-share fees, which the union required for non-members who refused union membership due to religious exemptions.

HIGHLIGHTS
  • The parties to the suit: The plaintiffs were James Imhoff and Lucille Imhoff. The defendants were the California Teachers Association and the Colusa Educators Association.
  • The issue: Are non-union member religious objectors entitled to refunds for compelled payments to third-party charities in lieu of fair-share fees required prior to Janus?
  • The presiding judge(s): The suit was dismissed prior to a circuit court judge appointment.
  • The outcome: The suit was dismissed voluntarily by the plaintiffs.

    • Procedural history

    The plaintiffs were James Imhoff and Lucille Imhoff. They were represented by Hellmich Law Group, Benbrook Law Group, PC Talcott Franklin PC, and Mitchell Law PLLC. The defendants were the California Teachers Association and the Colusa Educators Association. They were represented by Altshuler Berzon LLP.

    The plaintiffs in Imhoff v. California Teachers Association first filed their class-action lawsuit on November 7, 2018, in the U.S. District Court for the Eastern District of California. James Imhoff and Lucille Imhoff, both public school teachers, argued that when they refused to join the union due to their religious beliefs, they were forced to pay a third-party charity in lieu of fair-share fees in violation of their First Amendment rights. The plaintiffs sought to certify a class that included religious objectors forced to pay an equivalent amount of fair-share fees to third-party charities. Additionally, the suit sought refunds for all fees withheld from their paychecks and asked the court to declare Cal. Gov’t Code §3546.3 unconstitutional in light of the Supreme Court of the United States' ruling in Janus v. AFSCME.

    • November 7, 2018: The plaintiffs filed a complaint in the U.S. District Court for the Eastern District of California.
    • January 23, 2019: The case was transferred to the U.S. District Court for the Central District of California.
    • May 31, 2019: The defendants filed a motion to dismiss the case, arguing that charity fees in lieu of fair-share fees ended after the Janus ruling and that charity fees withheld prior to Janus were collected in good faith under the law at the time of collection.
    • July 1, 2019: The court granted the defendants’ motion to dismiss.
    • July 27, 2019: The plaintiffs appealed the case to the U.S. Court of Appeals for the Ninth Circuit.
    • September 25, 2019: The plaintiffs filed a motion to voluntarily dismiss the appeal.
    • October 1, 2019: The case was dismissed.

    For a list of available case documents, click here.


    Decision

    On July 1, 2019, Judge Josephine Staton dismissed the case and ruled in favor of the defendants. Judge Staton wrote the following in the court's opinion:

    “ IT IS HEREBY ADJUDGED that Plaintiffs’ claims are dismissed with prejudice, and JUDGMENT IS HEREBY ENTERED in favor of Defendants California Teachers Association and Colusa Educators Association, and against Plaintiffs James Imhoff and Lucille Imhoff. [1] ”
    —Judge Staton

    Josephine Staton was appointed to the court in 2010 by President Barack Obama (D).

    On October 1, 2019, the court dismissed the suit after the plaintiffs filed a motion to dismiss the suit voluntarily.


    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.[2]

    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.[2]

    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."[2]

    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

    Appeals court

    U.S. Court of Appeals for the Ninth Circuit, "Unopposed Motion to Dismiss Appeal," September 25, 2019

    Trial court

    Footnotes

    1. ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    2. ↑ 2.0 2.1 2.2 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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