## Facts

- Steele, a Black locomotive fireman employed by the Louisville & Nashville Railroad in Alabama, sued on behalf of himself and other similarly situated Black firemen.
- Under the Railway Labor Act (RLA), the Brotherhood of Locomotive Firemen and Enginemen was the exclusive bargaining representative for the craft of firemen.
- The Brotherhood barred Black firemen from membership but nonetheless represented the entire craft for collective bargaining purposes.
- In 1940, the Brotherhood initiated bargaining changes without informing Black firemen or giving them an opportunity to be heard.
- The union negotiated an agreement that favored white firemen and aimed to reduce Black firemen’s job security and advancement, including limiting desirable assignments and promotions to whites and facilitating Black firemen’s demotion or displacement.
- Steele alleged the Brotherhood refused to represent Black firemen fairly and acted in concert with the railroad to impose racially discriminatory contract terms.
- Alabama courts sustained a demurrer and dismissed the complaint; Steele sought review.

## Issues

1. Whether the RLA imposes on an exclusive bargaining representative a duty to represent all employees in the craft without racial discrimination.
2. Whether courts have jurisdiction to protect minority employees from a union’s breach of that duty, including through injunctive relief and damages.
3. Whether any RLA administrative process provides an exclusive remedy that would bar judicial relief.
4. Whether a union may exclude employees from membership yet still owe them fair and impartial representation in bargaining.

## Decision

- The Supreme Court unanimously reversed the Alabama Supreme Court.
- The Court held that the RLA imposes on a union acting as exclusive bargaining representative a duty to represent all employees in the craft without racial discrimination.
- The Court held that courts have jurisdiction to remedy violations of that duty.
- The Court held that Steele lacked an available administrative remedy under the RLA for this claim and that judicial remedies (including injunction and damages, when appropriate) are available.
- The Court held that although the union may control membership, it must represent nonmembers and minority employees fairly, impartially, and in good faith, without hostile discrimination, and must provide notice and an opportunity to be heard when necessary to satisfy that duty.

## Legal Principles

- An exclusive bargaining representative under the RLA owes a statutory duty of fair representation to all employees in the represented craft or class.
- The duty prohibits hostile discrimination, including discrimination based solely on race, in collective bargaining and contract formation with the carrier.
- Because the RLA grants the representative authority affecting all employees’ employment rights, that authority carries a corresponding obligation of equal, good-faith representation.
- A union’s power to set membership criteria does not diminish its duty to represent excluded employees in bargaining on equal terms.
- Where the RLA provides no adequate administrative remedy for a breach of the duty of fair representation, courts may grant traditional relief, including injunctions and damages.

## Conclusion

The Court recognized a federal cause of action under the RLA requiring exclusive bargaining representatives to represent all workers in the unit without racial discrimination and confirmed that courts may provide effective relief when a union uses its statutory bargaining power to disadvantage a minority of the craft.


Steele v. Louisville & Nashville R.R. Co., 323 U.S. 192 (1944)