## Facts

- UAW locals called lawful economic strikes at two Allis-Chalmers plants pursuant to union procedures.
- Some union members refused to strike, crossed picket lines, and continued working during the strikes.
- After the strikes ended, the locals disciplined those members under internal union processes by imposing fines of $20 to $100.
- The locals sued in state court to collect the fines.
- The collective bargaining agreement included a union-security clause requiring employees to be union members only “to the extent of paying” monthly dues.
- Allis-Chalmers filed unfair labor practice charges, alleging the fines and collection suits violated NLRA § 8(b)(1)(A) by restraining or coercing employees in their NLRA § 7 right to refrain from concerted activity.

## Issues

1. Whether a union violates NLRA § 8(b)(1)(A) by fining and suing to collect fines from full union members who work during a lawful economic strike.
2. Whether the analysis would differ for employees whose union “membership” is limited by a union-security clause to paying dues (question not decided).

## Decision

- The Supreme Court reversed the Seventh Circuit and upheld the NLRB’s dismissal of the unfair labor practice charges.
- A union does not violate § 8(b)(1)(A) by imposing reasonable fines on full members who refuse to honor an authorized strike.
- A union’s use of state-court litigation to collect such internal disciplinary fines does not, by itself, convert the conduct into unlawful coercion.
- The Court did not decide how § 8(b)(1)(A) applies to employees whose membership obligations are limited to dues payments under a union-security clause.

## Legal Principles

- NLRA § 8(b)(1)(A) prohibits union “restraint or coercion” of employees’ § 7 rights, but its proviso preserves a union’s authority to prescribe rules governing acquisition or retention of membership.
- Reasonable internal discipline of full members for violating union strike rules falls within the protected sphere of union membership governance rather than statutory coercion.
- Union membership may be treated as a voluntary, contractual relationship permitting enforcement of agreed-upon internal rules through member discipline.
- Internal union sanctions that do not employ employer power or affect job status are treated differently from conduct that interferes with employment rights protected by the NLRA.
- Seeking judicial enforcement of internal disciplinary fines is permissible where the underlying fines are lawful membership discipline.

## Conclusion

The Court held that NLRA § 8(b)(1)(A) does not bar a union from imposing reasonable fines on full members who cross a picket line during a lawful strike or from suing in state court to collect those fines, while reserving the separate question of employees whose union obligations are limited to paying dues.


National Labor Relations Board v. Allis-Chalmers Mfg. Co., 388 U.S. 175 (1967)