Supreme Court of the United States

Tunstall v. Brotherhood of Locomotive Firemen & Enginemen

December 18, 1944323 U.S. 210

Summary

Chief Justice Stone delivered the Court's opinion holding that the Railway Labor Act requires an exclusive bargaining representative to represent all employees in the craft without racial discrimination. The employee's claim to enforce that duty arises under federal law regulating commerce, giving the federal courts jurisdiction without diversity of citizenship. The Court also held that no available administrative remedy required exhaustion and that the complaint stated a cause of action entitling the employee to relief. It reversed and remanded to the Court of Appeals for consideration of unresolved jurisdictional questions. Justice Murphy concurred in the result for the reasons expressed in his concurrence in Steele v. Louisville & Nashville R. Co.

Holding

  • The bargaining representative's duty under the Railway Labor Act.. An exclusive bargaining representative must represent all employees in the craft without discrimination because of race, and the complaint alleging breach of that duty states a cause of action entitling the employee to relief.
  • Federal jurisdiction over the employee's nondiversity action.. The action arises under a federal law regulating commerce and falls within federal jurisdiction under Judicial Code § 24(8), 28 U.S.C. § 41(8).
  • Exhaustion of administrative remedies before equitable relief.. The employee has no available administrative remedy that must be exhausted before seeking equitable relief in federal court.

Docket 37

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