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Matthews v. United Teachers of Los Angeles

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Matthews v. United Teachers of Los Angeles
Case number: 2:18-cv-06793
Status: Terminated
Important dates
Filed: August 8, 2018
District court decision: May 8, 2019
Appeals court decision:
District court outcome
Unions are not liable to refund fair-share fees collected prior to Janus v. AFSCME.

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.

Matthews v. United Teachers of Los Angeles was terminated from the U.S. District Court for the Central District of California on May 22, 2019. The plaintiffs sought refunds for fair-share fees charged to non-union members before the Supreme Court of the United States' ruling in Janus v. AFSCME, and challenged California Government Code §1159, which released public employers from liability for union dues deductions.

HIGHLIGHTS
  • The parties to the suit: The plaintiffs were Tina Matthews and Paul Lessaro. The defendants were United Teachers Los Angeles, San Diego Education Association, National Education Association, and the California Teachers Association.
  • The issue: Must unions refund fair-share fees collected prior to Janus?
  • The presiding judge(s): Josephine Staton was assigned to the case. Staton was appointed to the court in 2010 by President Barack Obama (D).
  • The outcome: Unions are not liable to refund fair-share fees collected prior to Janus.

    • Procedural history

    The plaintiffs were Tina Matthews and Paul Lessaro. They were represented by Browne George Ross LLP. The defendants were United Teachers Los Angeles, San Diego Education Association, National Education Association, and the California Teachers Association. They were represented by Altshuler Berzon LLP.

    The plaintiffs in Matthews v. United Teachers of Los Angeles first filed their lawsuit on August 8, 2018, in the U.S. District Court for the Central District of California. The plaintiffs sought refunds for fair-share fees charged to non-union members before Janus v. AFSCME, and challenged California Government Code §1159, which released public employers from liability for union dues deductions.

    • August 8, 2018: The plaintiffs filed a complaint against all defendants.
    • December 14, 2018: The defendants filed a motion to dismiss, arguing that because fair-share fee collection ended there was no live controversy and that the plaintiffs’ state law claims were precluded by California Government Code §1159 and preempted by the Educational Employment Relations Act (EERA).
    • February 13, 2019: The court granted an intervention request by the California Attorney General, Xavier Becerra (D), in order to address the plaintiffs’ constitutional challenges to California Government Code §1159.
    • February 15, 2019: Intervenor Xavier Becerra filed a brief arguing that California Government Code §1159 did not violate the constitution.
    • May 8, 2019: The defendants’ motion to dismiss was granted.
    • May 22, 2019: The court entered a judgment in favor of the defendants.

    For a list of available case documents, click here.


    Decision

    On May 8, 2019, Judge Josephine Staton dismissed the case. Staton wrote the following in the court's opinion:

    “ In Crockett, the court found that the plaintiffs’ state law claims (indistinguishable from those asserted here) failed as a matter of law “because there can be no common law liability for conduct authorized by state statute.” Crockett involved Alaska’s version of the EERA and PERB, but the Court finds Crockett's Reasoning persuasive and applicable here. “ Janus does not change the fact that [the EERA] displaced any state common law tort claims that could have been brought with regard to [agency fees] collected prior to Janus.” Plaintiffs argue that “statutes authorizing the collection of agency fees are to be treated as though they never existed.” However, the Court “cannot ignore the fact that the Union Defendants’ collection of [agency fees] prior to Janus was authorized by state statute that was constitutional under controlling precedent. The court cannot now go back and impose tort liability under common law for that conduct.” Accordingly, the Court concludes that Plaintiffs’ common law tort claims are preempted by the EERA.

    [1]

    		”
    —Judge Josephine Staton

    Josephine Staton was appointed to the court 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.[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

    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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