## Facts

- District No. 1 of the National Marine Engineers’ Beneficial Association (NMEBA) regulated nominations and candidacy through district bylaws and the national union constitution.
- District bylaws permitted members to nominate only themselves for union office.
- The national constitution imposed additional candidacy qualifications based on tenure and service.
- Rank-and-file members who did not satisfy the candidacy qualifications claimed the rules effectively denied their statutory “right to nominate candidates.”
- The members sought injunctive relief in federal court under LMRDA Title I § 101(a)(1) (equal rights to nominate and vote), invoking Title I’s private enforcement provision, § 102.

## Issues

1. Whether federal district courts have jurisdiction under LMRDA § 102 to hear a Title I § 101(a)(1) claim attacking uniformly applied candidate-eligibility rules and a self-nomination rule as impairing members’ nomination rights.
2. Whether such challenges are governed by LMRDA Title IV (including § 401(e)), making the Secretary of Labor’s post-election procedure the exclusive enforcement route.

## Decision

- The Supreme Court reversed the court of appeals and reinstated dismissal for lack of jurisdiction under § 102.
- The Court held that § 101(a)(1) targets discrimination in the electoral process; it does not authorize judicial review of uniformly applied candidate-eligibility qualifications.
- The Court held that candidacy qualifications and related nomination/eligibility complaints are addressed by Title IV, and enforcement generally must proceed through a post-election complaint to the Secretary of Labor, followed by a suit brought by the Secretary if warranted.

## Legal Principles

- Title I § 101(a)(1) protects union members against discriminatory denial of equal rights to nominate, vote, and participate; it is violated only where members are treated unequally in the exercise of those rights.
- A claim that eligibility requirements are overly restrictive, when imposed uniformly on all members, does not state a Title I “equal rights” violation.
- Candidate eligibility standards are governed by Title IV § 401(e), which permits reasonable qualifications uniformly imposed.
- Title IV establishes a specialized enforcement scheme that generally makes the Secretary of Labor’s post-election process the exclusive remedy for Title IV election challenges, after exhaustion (or pursuit for the statutory period) of internal union remedies.

## Conclusion

The Court held that members cannot use Title I’s private right of action to litigate the substance of uniformly applied union candidacy qualifications; such disputes fall within Title IV and must be pursued through the Secretary of Labor’s post-election enforcement procedure.


Calhoon v. Harvey, 379 U.S. 134 (1964)