## Facts

- McLean Trucking Company and Chauffeurs, Teamsters and Helpers, Local No. 391 operated under a collective-bargaining agreement governing work at McLean terminals.
- During terminal closings and reorganizations, certain drivers were transferred to Winston-Salem, North Carolina and granted “special seniority rights” over temporarily laid-off inactive employees.
- After layoffs and recalls, some transferred drivers lost their special seniority and filed a grievance alleging McLean violated the collective-bargaining agreement by preferring inactive employees.
- A grievance committee directed McLean to recall the drivers and honor special seniority; McLean briefly complied, then again recalled inactive employees in a manner that displaced the drivers in a later layoff.
- When drivers sought further grievance relief, the Union refused to submit the new charges to the grievance committee, stating the issues had already been resolved.
- The drivers sued, alleging McLean breached the collective-bargaining agreement under LMRA § 301 and the Union breached its duty of fair representation, seeking injunctive relief and compensatory damages (lost wages and benefits) and demanding a jury trial.
- After McLean’s bankruptcy, claims against McLean and all injunctive requests were dismissed, leaving only a damages claim against the Union.
- The Union moved to strike the jury demand; the district court denied the motion, and the Fourth Circuit affirmed.

## Issues

1. Whether the Seventh Amendment guarantees a jury trial for employees suing a union for breach of the duty of fair representation when the employees seek compensatory damages such as backpay and lost benefits.

## Decision

- The Supreme Court affirmed the Fourth Circuit.
- The Court held that the Seventh Amendment entitles employees to a jury trial on a duty of fair representation claim seeking compensatory damages.
- Applying the Seventh Amendment framework, the Court treated the nature of the remedy as the most important factor.
- The Court characterized the requested relief—backpay and lost benefits—as traditional legal damages, not equitable restitution, because the money sought was not held by the Union but represented wages and benefits the employees would have received from the employer absent the Union’s alleged breach.
- The Court noted that recovering such damages requires proving both an employer contract violation and a union breach in handling the grievance, reinforcing the action’s legal character.
- A dissent would have treated the union-member relationship as primarily equitable (trust-like) and would have rejected a jury right even where money damages were requested.

## Legal Principles

- Seventh Amendment jury-trial analysis compares the action to historical actions at law and in equity and then examines the remedy sought, with the remedy inquiry carrying greater weight.
- Compensatory damages for lost wages and benefits are generally legal relief and support a Seventh Amendment jury right absent features that make the monetary award equitable.
- In duty of fair representation suits seeking backpay-type damages, the award is not treated as equitable restitution when the union is not the holder of the claimed funds and the damages represent losses the employee would have received from the employer.
- In a hybrid LMRA § 301/duty of fair representation theory, an employee’s recovery for monetary loss depends on proving both the employer’s contract breach and the union’s representational breach, supporting classification as legal for jury-trial purposes.

## Conclusion

The Court held that employees who sue a union for breach of the duty of fair representation and seek compensatory damages such as backpay and lost benefits are entitled to a jury trial under the Seventh Amendment because the remedy is legal in character.


Chauffeurs, Teamsters & Helpers, Local No. 391 v. Terry, 494 U.S. 558 (1990)