United Food and Commercial Workers Union Local 751 v. Brown Group, Inc., Dba Brown Shoe Co.

Summary

The Court unanimously held, in an opinion by Justice Souter, that the WARN Act authorizes a union to sue for damages on behalf of its employee-members and that Congress constitutionally displaced the third prong of the associational-standing test for those suits. That requirement, concerning the need for individual members' participation, is prudential rather than constitutional and therefore may be removed by statute. The Court reversed the Court of Appeals and remanded. It did not decide whether the union independently had standing based on direct injury or whether a simplified damages claim could satisfy the third prong without congressional authorization. There were no separate opinions.