## Facts

- African-American railroad employees alleged their union, the exclusive bargaining representative under the Railway Labor Act, refused to represent them fairly because of race.
- The employees claimed the railroad purported to abolish jobs held by Black workers but then staffed the same jobs with white employees, sometimes rehiring Black workers only with loss of seniority.
- The complaint alleged the union did not process grievances or protect employment and seniority rights despite repeated requests, solely because of race.
- The employees sued union officers, the local union, and the parent union in a class capacity, seeking nondiscriminatory representation and related relief; the railroad was not named as a defendant.
- The district court dismissed for lack of jurisdiction, reasoning the National Railroad Adjustment Board had exclusive jurisdiction; the Fifth Circuit affirmed.

## Issues

1. Whether the National Railroad Adjustment Board has exclusive jurisdiction over an action by employees against their union alleging racially discriminatory breach of the duty of fair representation.
2. Whether the railroad was an indispensable party requiring dismissal for failure to join it.
3. Whether the complaint failed to state a claim under Rule 8(a) and Rule 12(b)(6) because it alleged discrimination in general terms without detailed supporting facts.

## Decision

- The Supreme Court reversed and remanded.
- Federal courts have jurisdiction over employees’ claims against their bargaining representative for breach of the statutory duty of fair representation; the Adjustment Board’s exclusive jurisdiction is limited to disputes between employees and carriers.
- The railroad was not an indispensable party to a fair-representation action against the union.
- The complaint sufficiently stated a claim under the Federal Rules because it provided fair notice of the claim and its grounds; detailed factual pleading was not required at the motion-to-dismiss stage.

## Legal Principles

- An exclusive bargaining representative under the Railway Labor Act owes a statutory duty to represent all employees in the bargaining unit fairly and without racial discrimination, and courts may enforce that duty.
- The National Railroad Adjustment Board’s exclusive jurisdiction extends to employee–carrier disputes, not to claims by employees against their union for discriminatory representation.
- Under Rule 8(a), a complaint need only provide a short and plain statement giving the defendant fair notice of the claim and its grounds; it need not plead detailed evidentiary facts.
- A Rule 12(b)(6) dismissal is improper unless it appears beyond doubt that the plaintiff can prove no set of facts consistent with the complaint that would entitle the plaintiff to relief.
- The availability of other avenues (such as employees pursuing grievances themselves or suing the employer for contract breach) does not excuse a union’s discriminatory refusal to represent employees.

## Conclusion

The Court held that employees may sue their union in federal court for racially discriminatory breach of the Railway Labor Act duty of fair representation, without joining the carrier, and that general allegations providing fair notice satisfy Rule 8 and should not be dismissed under Rule 12(b)(6) absent certainty that no facts could support relief.


Conley v. Gibson, 355 U.S. 41 (1957)