Supreme Court of the United States
Association of Westinghouse Salaried Employees v. Westinghouse Electric Corp.
March 28, 1955348 U.S. 437
Summary
The Court affirmed the Third Circuit, holding that § 301 of the Labor Management Relations Act does not grant federal jurisdiction over a union’s suit on behalf of employees for unpaid wages because the claim rests on individual employment contracts, not a breach of the collective bargaining agreement. The decision rests on a textual and legislative‑history analysis of § 301 as a procedural grant of jurisdiction only.
Holding
- Whether § 301 of the Labor Management Relations Act confers federal jurisdiction over a union’s suit on behalf of employees for unpaid wages arising from individual employment contracts.. No. § 301 is a procedural grant of jurisdiction limited to actions arising from a breach of the collective‑bargaining contract between the union and the employer; claims based on individual hiring contracts are outside its scope.
- Whether the union is a proper plaintiff under Rule 17(a) to sue on behalf of its members in such an action.. The Court did not need to decide this issue because the suit lacked jurisdiction; however, it noted that the union was a proper plaintiff under Rule 17(a) for a claim that fell within § 301.
Docket 51
Cited authorities
- 28 U.S.C. § 2202
- 61 Stat. 156
- 29 U.S.C. § 185
- 62 Stat. 964
- 28 U.S.C. §§ 2201
- 28 U.S.C. § 1331
- 45 Yale L.J. 393
- 62 Stat. 934