## Facts

- A union scheduled an executive board election for late 1980.
- At the nomination meeting, admission was limited to members who could produce a computerized dues-payment receipt; some members were excluded.
- A dispute also arose concerning the office for which a member had been nominated.
- Members protested through internal union processes; the union denied the protest.
- After ballots were mailed but before votes were counted, members sued in federal district court alleging violations of Title I of the Labor-Management Reporting and Disclosure Act of 1959 (LMRDA) and sought injunctive relief.
- The district court issued a temporary restraining order halting the election, later declared the election invalid, ordered a new election with detailed procedures, and appointed outside arbitrators to supervise implementation.
- The First Circuit largely affirmed.
- The Supreme Court granted certiorari to determine the proper relationship between Title I private suits and Title IV’s election-remedy scheme.

## Issues

1. Whether union members may sue under LMRDA Title I in an election dispute when the requested relief would effectively challenge or control the conduct or validity of the election.
2. How Title I’s authorization of “appropriate” relief, including injunctions, interacts with Title IV’s exclusive post-election remedy administered through the Secretary of Labor.

## Decision

- The Court held that Title I private suits may proceed during an election to vindicate Title I rights, but the permissibility depends on the nature of the relief sought.
- The Court ruled that federal courts may not, in a Title I action, grant relief that is functionally equivalent to Title IV relief—such as invalidating an election, ordering a new election, or imposing detailed supervisory election procedures with outside oversight.
- The Court concluded the district court exceeded Title I remedial authority by declaring the election invalid and prescribing a comprehensive court-supervised rerun election.
- The judgment was affirmed in part and reversed (or vacated) in part.

## Legal Principles

- Title I (LMRDA §§ 101–102) protects individual member rights and permits private suits for “appropriate” relief, including injunctions, to remedy violations of those rights.
- Title IV (LMRDA §§ 401–403) establishes a centralized post-election enforcement scheme; challenges seeking to set aside an election already conducted must proceed exclusively through an action brought by the Secretary of Labor.
- Courts must distinguish between (a) narrowly targeted Title I remedies addressing discrete infringements of member rights and (b) election-invalidating or election-supervising remedies reserved to Title IV.
- A live Title I controversy may persist through collateral relief (e.g., damages, fees, costs, or declaratory relief) even when comprehensive election relief is unavailable in a private action.

## Conclusion

The Court preserved Title I private enforcement during union elections for remedies tailored to member-rights violations, while barring district courts from using Title I to invalidate elections or impose broad, Secretary-like supervision that Congress reserved to Title IV proceedings initiated by the Secretary of Labor.


Loc. No. 82, Furniture & Piano Moving, Furniture Store Drivers, Helpers, Warehousemen & Packers v. Crowley, 467 U.S. 526 (1984)