## Facts

- Local 201, a Wichita, Kansas carpenters’ local union, was a subordinate body of the United Brotherhood of Carpenters and Joiners of America (UBC), an international labor organization.
- Wichita-area locals considered forming or participating in a district council; one benefit for Local 201 members would have been avoiding a fee otherwise required to work on missile sites.
- District-council participation would also require an increase in Local 201 members’ monthly dues.
- After learning the dues consequences, Local 201 members voted to oppose the dues increase and to withdraw from (or not participate in) the district council arrangement.
- The UBC president directed Local 201 to affiliate with the district council and to implement the dues increase.
- Local 201 did not comply with the directive.
- UBC imposed a trusteeship over Local 201 and appointed a trustee to carry out the president’s orders, displacing local control.
- UBC’s constitution and bylaws gave the international general supervisory authority over subordinate bodies, but did not contain a specific provision authorizing trusteeships.
- Local 201 filed suit in federal district court challenging the trusteeship; the district court held the trusteeship invalid, and UBC appealed to the Tenth Circuit.

## Issues

1. Whether UBC’s general constitutional authority to regulate subordinate bodies carried an implied power to impose a trusteeship when the constitution contained no express trusteeship provision.
2. Whether the trusteeship satisfied the Labor-Management Reporting and Disclosure Act (LMRDA) Title III requirements that a trusteeship be established and administered in conformity with the union’s constitution and bylaws and only for a “legitimate object” listed in 29 U.S.C. § 462.

## Decision

- The Tenth Circuit affirmed the judgment for Local 201 and left in place relief invalidating the trusteeship.
- The court concluded that broad supervisory language in UBC’s constitution and bylaws did not supply trusteeship authority where no trusteeship power was expressly granted (or clearly implied).
- The court also concluded that the trusteeship could not be sustained under LMRDA Title III because it was not shown to be imposed for a statutory “legitimate object,” but instead functioned to force a dues increase and district-council affiliation against the local membership’s vote.

## Legal Principles

- A trusteeship is a severe intervention that displaces local self-government; authority to impose it must come from the labor organization’s constitution and bylaws and is not lightly inferred from general supervisory clauses.
- Under LMRDA Title III, a trusteeship is lawful only if it is established and administered in conformity with the organization’s constitution and bylaws and only for the “legitimate objects” identified in 29 U.S.C. § 462 (such as correcting corruption or financial malpractice, assuring performance of collective-bargaining duties, restoring democratic procedures, or otherwise carrying out the labor organization’s lawful objectives).
- Using a trusteeship mainly to override a local union’s membership decision on internal policy questions—such as dues levels or voluntary affiliation with a district council—does not, without more, meet the statutory requirement of a “legitimate object.”

## Conclusion

United Brotherhood of Carpenters v. Brown holds that an international union may not place a local union in trusteeship based solely on general supervisory language in its constitution, nor may it use a trusteeship primarily to compel increased dues and district-council affiliation contrary to the local membership’s vote; absent clear constitutional authorization and a purpose within 29 U.S.C. § 462, the trusteeship is invalid.


United Brotherhood of Carpenters v. Brown, 343 F.2d 872 (1965)