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Martin v. California Teachers Association

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Martin v. California Teachers Association
Case number: 0:19-cv-55761
Status: Pending before the U.S. Court of Appeals for the Ninth Circuit
Important dates
Filed: July 14, 2018
District court decision: June 6, 2019
Appeals court decision: Pending
District court outcome
Unions are not liable to refund union dues collected before Janus v. AFSCME, and exclusive representation does not violate antitrust laws or constitutional rights.
Appeals court outcome
Pending

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.

Martin v. California Teachers Association was appealed on July 3, 2019, and is pending before the U.S. Court of Appeals for the Ninth Circuit. The suit sought refunds for union dues collected from members who would not have joined the union if non-members were not charged fair-share fees, and also argued that exclusive representation violated the plaintiffs’ First Amendment rights and antitrust laws.[1]

HIGHLIGHTS
  • The parties to the suit: The plaintiffs are Lori Bonner, Philip David Glick, Kimberly Jolie, and Michael Martin. The defendants are the California Teachers Association (CTA), National Education Association, Riverside City Teachers Association, and Attorney General Xavier Becerra (D).
  • The issue: Must unions refund dues collected before Janus to members who would not have joined if non-members were not charged fair-share fees?
  • The presiding judge(s): Josephine Staton was assigned to the case. Staton was appointed in 2010 by President Barack Obama (D).
  • The outcome: This lawsuit is pending before the U.S. Court of Appeals for the Ninth Circuit.

    • Procedural history

    The plaintiffs are Lori Bonner, Philip David Glick, Kimberly Jolie and Michael Martin. They are represented by Talcott Franklin PC, Benbrook Law Group, PC, Hellmich Law Group, and Mitchell Law PLLC. The defendants are the California Teachers Association, National Education Association, Riverside City Teachers Association, and Attorney General Xavier Becerra (D). The California Teachers Association, National Education Association, and Riverside City Teachers Association are represented by Altshuler Berzon LLP. Xavier Becerra is represented by the Office of the California Attorney General.

    The plaintiffs in Martin v. California Teachers Association first filed their class-action lawsuit on July 14, 2018, in the U.S. District Court for the Eastern District of California. The plaintiffs sought a classwide recovery of all union dues and fair-share fees collected by the CTA from members and non-members against their will, which they argued was a violation of their First Amendment rights under Janus v. AFSCME. Likewise, the plaintiffs argued that the CTA violated their rights by automatically enrolling them in a voluntary contribution program used to subsidize political speech. Further, they argued that the Riverside Unified School District must honor employees’ requests for union resignation without requiring that employees submit resignation requests to the union. Additionally, they argued that collective bargaining through exclusive representation violated the First Amendment, and argued that the CTA’s collective bargaining agreement, which prevented non-union members from negotiating their own contracts, violated antitrust laws.[1]

    • July 14, 2018: Plaintiff Martin filed a complaint against the California Teachers Association, National Education Association, Riverside City Teachers Association, Eric Banks, Xavier Becerra, Mark Gregersen, Arthur A. Krantz, Erich Shiners, Priscilla Winslow, Riverside Unified School District, and Edmund G. Brown.
    • October 17, 2018: The court transferred the suit to the U.S. District Court for the Central District of California.
    • November 5, 2018: Defendants California Teachers Association, National Education Association, and Riverside City Teachers Association filed a motion to dismiss the plaintiffs’ antitrust claim for failing to state a claim upon which relief may be granted.
    • November 6, 2018: The plaintiffs filed an amended complaint, adding Lori Bonner, Philip David Glick, and Kimberly Jolie as plaintiffs.
    • December 4, 2018: Defendant Edmund G. Brown was dismissed from the suit by the plaintiffs.
    • December 5, 2018: The defendants filed motions to dismiss.
    • February 8, 2019: The plaintiffs filed a motion to stay the case pending a decision in a related case, Danielson v. Inslee.
    • March 1, 2019: The plaintiffs dismissed the defendant Riverside Unified School District from the suit. Additionally, the plaintiffs filed oppositions to the motions to dismiss.
    • March 15, 2019: The defendants filed replies in support of the motions to dismiss.
    • May 8, 2019: The court granted the defendants’ motion to dismiss, dismissing all the plaintiffs’ claims except for their second claim regarding the voluntary contribution program.
    • May 23, 2019: The plaintiffs filed a stipulation of dismissal, dismissing their second claim.
    • June 6, 2019: The court entered a judgment in favor of the defendants.
    • July 3, 2019: The plaintiffs appealed the court’s decision to the U.S. Court of Appeals for the Ninth Circuit.
    • March 31, 2020: Defendants Mark Gregersen, Eric Banks, Priscilla Winslow, Erich Shiners, and Arthur A. Krantz were dismissed from the suit voluntarily by the plaintiffs.

    For a list of available case documents, click here.


    Decision

    On May 8, 2019, Judge Josephine Staton granted the defendants’ motion to dismiss. Staton wrote the following in the court's opinion:

    “ Essentially, though the Martin Plaintiffs did not actually pay agency fees, they argue that such fees were subsumed within their membership dues. (Id.) Thus, “they had no choice in whether to pay the mandatory portion of the dues that was imposed on every member of their bargaining unit.” (Id.) First, because the Court concludes that the Union Defendants have a good-faith defense to retroactive monetary relief based on Janus, the Martin Plaintiffs’ claim fails as a matter of law. Further, the Court agrees with Crockett, which held that an indistinguishable claim failed. In short, the Martin Plaintiffs voluntarily chose to pay membership dues in exchange for certain benefits, and “[t]he fact that plaintiffs would not have opted to pay union membership fees if Janus had been the law at the time of their decision does not mean their decision was therefore coerced.”… Contrary to Martin’s contention, Janus does not hold that employees have the right to resign from a union however they want, regardless of state laws that prescribe clear, common-sense procedures for doing so. Submitting a writing to the Union Defendants to halt payroll deductions is not a burdensome requirement. Because the deductions go to the Union Defendants, it makes sense that the halting of such deductions must be communicated to the Union Defendants rather than the school districts… Further, “[t]he labor of a human being is not a commodity or article of commerce.” 15 U.S.C. §17. “Therefore, ‘restraints on the sale of the employee’s services to the employer’—those employment terms set forth in a collective bargaining agreement—‘are not themselves combinations or conspiracies in the restraint of trade or commerce under the Sherman Act’ even if they ‘curtail the competition among employees.’”[2][3] ”
    —Judge Josephine Staton

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

    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.[4]

    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.[4]

    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."[4]

    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

    Trial court

    Footnotes

    1. ↑ 1.0 1.1 CourtListener, “First Amended Class-Action Complaint,” accessed May 12, 2020
    2. ↑ PacerMonitor, “Order Granting Defendants’ Motion to Dismiss,” accessed May 12, 2020
    3. ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    4. ↑ 4.0 4.1 4.2 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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