## Facts

- A local union’s constitution required candidates for union office to have attended at least one-half of the union’s regular monthly meetings for the three years preceding the election (18 of 36 meetings).
- The local had about 660 members in good standing.
- The attendance requirement made 96.5% of the membership ineligible to run for office; only 23 members were eligible, including nine incumbents.
- The Secretary of Labor alleged the rule violated LMRDA Title IV, § 401(e), which guarantees that every member in good standing is eligible to be a candidate and hold office, subject only to “reasonable qualifications.”
- The Secretary sought to set aside the 1970 officer election conducted under the challenged requirement.

## Issues

1. Whether a union rule requiring attendance at one-half of regular meetings over the prior three years is a “reasonable qualification” under LMRDA § 401(e).
2. Whether a candidacy restriction’s legality under Title IV turns on its practical effect on member choice rather than proof that it entrenched incumbents or produced corrupt leadership.

## Decision

- The Supreme Court affirmed the Seventh Circuit and held the meeting-attendance requirement was not a “reasonable qualification” under § 401(e).
- The Court concluded that excluding 96.5% of members from candidacy unlawfully restricted members’ statutory right to run for office and limited members’ freedom to choose leaders.
- The Court treated the restriction’s severe practical impact as decisive, including the likelihood that it discouraged candidacies by requiring members to plan potential runs far in advance of an election.
- The Court rejected the argument that invalidation required proof that incumbents were actually entrenched or that the rule enabled corruption.
- The Court sustained the Secretary’s Title IV challenge to the election conducted under the unlawful restriction.

## Legal Principles

- LMRDA § 401(e) protects broad eligibility to run for union office, allowing only “reasonable qualifications” consistent with the Act’s objective of free and democratic elections.
- The reasonableness of a candidacy qualification is assessed in context, with primary attention to its practical effect on the size and openness of the eligible candidate pool and on members’ freedom of choice.
- A qualification that excludes nearly the entire membership from candidacy is unreasonable because it restricts competitive elections and the ability of members to replace incumbents.
- Title IV prohibits procedures that unduly restrict free choice among candidates without requiring proof that the restrictions succeeded in entrenching leadership or enabling wrongdoing.
- Claimed justifications (such as encouraging attendance or ensuring knowledgeable leadership) cannot validate a rule whose operation substantially limits candidacy and frustrates democratic competition.

## Conclusion

The Court held that a three-year meeting-attendance requirement barring 96.5% of members from running for local union office violated LMRDA § 401(e) because it was not a reasonable qualification and impermissibly restricted members’ freedom to choose union leadership through open, competitive elections.


Local 3489, United Steelworkers of Am. v. Usery, 429 U.S. 305 (1977)