## Facts

- Local 75 of the Sheet Metal Workers’ International Association faced serious financial problems, and the International imposed a trusteeship.
- The International appointed Richard Hawkins as trustee with authority under the union constitution to supervise the local and suspend officers and business representatives.
- Hawkins proposed a dues increase to address the local’s finances.
- At a special membership meeting, Edward Lynn, an elected business representative, spoke against the dues increase; the membership voted the proposal down.
- Five days later, Hawkins removed Lynn “indefinitely,” citing Lynn’s outspoken opposition to the dues increase.
- After exhausting internal union remedies, Lynn sued under Title I of the Labor-Management Reporting and Disclosure Act of 1959 (LMRDA), alleging retaliation for protected speech.

## Issues

1. Whether removing an elected union business representative in retaliation for his speech at a union meeting violates Title I of the LMRDA.
2. Whether a trusteeship and the trustee’s authority can justify such a removal notwithstanding Title I’s protections.
3. Whether precedent permitting removal of appointed union employees for political reasons extends to retaliatory removal of an elected official.

## Decision

- The Supreme Court affirmed the Ninth Circuit.
- The Court held that removing an elected business representative in retaliation for protected statements at a union meeting violates Title I of the LMRDA.
- The Court rejected the union’s reliance on precedent involving discharge of appointed union employees.
- The Court concluded that a trusteeship does not suspend Title I speech protections.

## Legal Principles

- Title I of the LMRDA protects union members’ rights of speech and assembly in union affairs, and retaliation that penalizes protected speech can unlawfully interfere with those rights.
- Retaliatory removal of an elected union official burdens Title I rights by coercing a choice between exercising protected speech and retaining union office.
- Removal of an elected official also injures members’ statutory interests by depriving them of their chosen representative and by chilling debate and participation in union governance.
- Precedent allowing politically motivated discharge of appointed union staff does not control where the targeted official is elected and the removal is retaliatory.
- The existence of a trusteeship and broad trustee authority does not, without clear congressional authorization, curtail Title I rights, particularly where members retain the right to vote on union matters such as dues.

## Conclusion

The Court held that Title I of the LMRDA forbids removing an elected union business representative in retaliation for speech made at a union meeting, because the action penalizes protected expression, chills member participation, and undermines representative choice even during a trusteeship.


Sheet Metal Workers’ Int’l Ass’n v. Lynn, 488 U.S. 347 (1989)