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Mattos v. AFSCME Council 3

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Mattos v. AFSCME Council 3
Case number: 22-567
Status: Appealed to U.S. Supreme Court
Important dates
Filed: Sept. 3, 2019
District court decision:
April 27, 2020
Appeals court decision:
Sept. 16, 2022
Supreme Court decision:
Pending
District court outcome
Unions are not liable to refund fair-share fees collected prior to the Supreme Court's ruling in Janus v. AFSCME.
Appeals court outcome
The Fourth Circuit upheld the district court's ruling.
Supreme 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.

Mattos v. AFSCME Council 3 was decided by the U.S. Court of Appeals for the Fourth Circuit on September 16, 2022. The Fourth Circuit upheld the U.S. District Court for the District of Maryland's April 2020 ruling in favor of AFSCME Council 3. The plaintiffs had sought a refund of agency fees collected by the union from non-union members before the U.S. Supreme Court's 2018 ruling in Janus v. AFSCME.[1][2][3]

The plaintiffs appealed to the U.S. Supreme Court on December 15, 2022.[4]

HIGHLIGHTS
  • The parties to the suit: The plaintiffs are Gary Mattos, Doris Beegle, Vickie Boggs, Bradley French, Carla Gurganus, Steven Hale, John Hill, Benjamin Ickes, Michelle Lambert, Jessica Merritt, John Meyers, Carole Miller, Melissa Potter, Jim Rieman, Laurie Rubin, Joyce Stoner, Russell Stott, Larry Teets, and Kimberly Griffith. The defendant is AFSCME Council 3.
  • The issue: Must unions refund agency fees collected from non-union members before Janus?
  • The presiding judges: U.S. District Judge George L. Russell III presided over the district court proceedings. A three-judge panel—U.S. Circuit Judge Robert King, U.S. Circuit Judge Steven Agee, and Senior U.S. Circuit Judge Barbara Keenan—presided over the case in the Fourth Circuit.
  • The outcome: The Fourth Circuit upheld the district court's dismissal of the case. The plaintiffs appealed to the Supreme Court.

    • Procedural history

    The plaintiffs are Gary Mattos, Doris Beegle, Vickie Boggs, Bradley French, Carla Gurganus, Steven Hale, John Hill, Benjamin Ickes, Michelle Lambert, Jessica Merritt, John Meyers, Carole Miller, Melissa Potter, Jim Rieman, Laurie Rubin, Joyce Stoner, Russell Stott, Larry Teets, and Kimberly Griffith. Attorneys from the Liberty Justice Center and the National Right To Work Legal Defense Foundation represent the plaintiffs. The defendant is AFSCME Council 3. Attorneys from Bredhoff & Kaiser, PLLC represent the defendant.[1][2]

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

    • September 3, 2019: The plaintiffs filed a class-action complaint against AFSCME Council 3 in the U.S. District Court for the District of Maryland.
    • October 18, 2019: The defendant filed a motion to dismiss.
    • November 1, 2019: The plaintiffs filed a response to the defendant's motion to dismiss.
    • November 15, 2019: The defendant filed a reply to the plaintiffs' response.
    • April 27, 2020: U.S. District Judge George L. Russell III granted the defendant's motion to dismiss.
    • May 5, 2020:The plaintiffs appealed the ruling to the U.S. Court of Appeals for the Fourth Circuit. The appeal was docketed on May 7.
    • September 16, 2022: A Fourth Circuit panel upheld the district court’s ruling in an unpublished per curiam opinion.
    • December 15, 2022: The plaintiffs appealed to the U.S. Supreme Court.

    For a list of available case documents, click here.

    Decision

    District court decision

    On April 27, 2020, U.S. District Judge George L. Russell III dismissed the suit. Russell wrote the following in the court's opinion:[5]

    “

    For their part, Plaintiffs maintain they are nonetheless entitled to damages under § 1983 because the rule in Janus applies retroactively. However, whether Janus applies retroactively is far from clear, as the Janus Court did not state that it was applying the new rule to the parties before it, but simply remanded to the lower court for 'further proceedings consistent with this opinion.' ... Following from this, at least three federal district courts have noted there is a 'strong argument' that the rules of retroactivity would not permit an award of 'retrospective monetary relief' based on conduct that predated the Janus decision. ...

    Moreover, any retroactive effect of Janus would not preclude application of the good-faith defense. ... Because the Court finds that AFSCME is entitled to the good-faith defense, Plaintiffs’ argument that Janus applies retroactively cannot save the Complaint from dismissal.

    ...

    Turning to Plaintiffs’ claim for declaratory relief, AFSCME contends that Plaintiffs do not have standing to seek a judgment declaring AFSCME’s past conduct unconstitutional. Specifically, AFSCME notes that Plaintiffs’ Complaint does not challenge any ongoing conduct by AFSCME, but only the past collection of agency fees from non-members, which ceased upon the Supreme Court’s decision in Janus.

    ...

    In sum, Plaintiffs’ § 1983 claim for damages is barred by the good-faith defense, and Plaintiffs lack standing to seek declaratory judgment. Accordingly, the Court will grant AFSCME’s Motion to Dismiss. [6]

    		”

    President Barack Obama (D) appointed Russell to the court.

    Appellate court decision

    On September 16, 2022, a three-judge panel—U.S. Circuit Judge Robert King, U.S. Circuit Judge Steven Agee, and Senior U.S. Circuit Judge Barbara Keenan—upheld the district court’s ruling. The judges wrote in the unpublished per curiam opinion:[7]

    “

    On appeal, Appellants argue that the district court erred in allowing AFSCME to assert a good-faith defense to its 42 U.S.C. § 1983 claim, and that this court should decline to recognize a good-faith defense. However, after Appellants' brief was filed, we decided the issue of whether a union can assert a good-faith defense in a Janus claim under § 1983 in Akers v. Maryland State Educ. Ass'n [in 2021.] ... We concluded, in accordance with six other courts of appeals, that the good-faith defense is available to private parties sued under § 1983, and that the union was entitled to assert the good-faith defense in the Janus context. ... Because Akers directly applies to the legal question at issue here, we hold that the district court did not err in determining that AFSCME was entitled to assert a good-faith defense and granting AFSCME’s motion to dismiss.

    Accordingly, we affirm the district court’s order.[6]

    		”

    President Bill Clinton (D) appointed King to the court, President George W. Bush (R) appointed Agee, and Obama appointed Keenan.

    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 PacerMonitor, "Mattos et al v. American Federation of State, County and Municipal Employees, AFL-CIO, Council 3," accessed September 23, 2022
    2. ↑ 2.0 2.1 2.2 PacerMonitor, "Gary Mattos v. American Federation of State," accessed September 23, 2022
    3. ↑ 3.0 3.1 Liberty Justice Center, "Complaint (Class Action)," accessed May 13, 2020
    4. ↑ 4.0 4.1 Supreme Court of the United States, "Petition for Writ of Certiorari," December 15, 2022
    5. ↑ U.S. District Court for the District of Maryland, "Memorandum to Counsel Re: Gary Mattos, et al. v. American Federation of State, County and Municipal Employees, AFL-CIO, Council 3," April 27, 2020
    6. ↑ 6.0 6.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    7. ↑ U.S. Court of Appeals for the Fourth Circuit, "No. 20-1531," September 16, 2022
    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
    v • e
    Public-sector union policy in the United States
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