2nd Circ. Nixes Wannabe Member's LMRDA Suit Against Union

Law360, New York (February 3, 2014, 6:30 PM EST) -- The Second Circuit clarified Monday that both union members and “union members in substance” can bring claims under the Labor-Management Reporting & Disclosure Act, but found that a film industry driver suing a Teamsters Local over alleged retaliation was neither.

The appeals court upheld the dismissal of driver John Brady's claims that the International Brotherhood of Teamsters, Theatrical Drivers and Helpers Local 817 had violated the LMRDA by denying him membership in retaliation for complaints about a union member.

The court found that a New York...
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