## Facts

- After a contentious union election in which reform candidate Edward Sadlowski received substantial financial support from outside the union, the United Steelworkers amended its constitution to adopt an “outsider rule.”
- The outsider rule prohibited candidates for union office from accepting campaign contributions from nonmembers.
- The rule established an internal committee to enforce the restriction, with decisions described as final and binding within the union.
- Sadlowski and other members challenged the rule under the Labor-Management Reporting and Disclosure Act of 1959 (LMRDA) “Bill of Rights,” contending it impeded election-related advocacy and organization.
- The challengers argued the restriction operated broadly, including by preventing the use of nonmember funds to support campaign-related litigation.
- The union defended the rule as a measure aimed at preventing undue outside influence over union elections and protecting internal self-government, invoking LMRDA § 101(a)(2)’s proviso permitting “reasonable rules” concerning members’ responsibilities to the union.

## Issues

1. Whether a union rule barring candidates from accepting campaign contributions from nonmembers violates LMRDA § 101(a)(2)’s protections for members’ speech and assembly, or is permissible as a “reasonable” rule under the statutory proviso.
2. Whether LMRDA § 101(a)(2) incorporates the full body of First Amendment doctrine governing campaign contributions, requiring constitutional-level scrutiny of union election rules.

## Decision

- The Supreme Court reversed the court of appeals insofar as it invalidated the outsider rule under LMRDA § 101(a)(2).
- The Court held the outsider rule did not violate § 101(a)(2) because it was rationally related to a legitimate purpose and therefore protected by § 101(a)(2)’s proviso allowing “reasonable rules.”
- The Court rejected the argument that § 101(a)(2) incorporates the full scope of First Amendment campaign-finance doctrine; the statute requires reasonableness, not strict constitutional tests.
- The Court acknowledged the rule could burden protected interests and could reduce insurgents’ campaign effectiveness, but concluded the burden was not so severe as to make the rule unreasonable given the union’s legitimate interest in insulating itself from nonmember influence.

## Legal Principles

- LMRDA § 101(a)(2) protects union members’ speech and assembly rights but expressly permits unions to adopt “reasonable rules” regarding members’ responsibilities to the organization and conduct affecting the union’s institutional functions.
- A union election rule may affect protected expressive activity and still be lawful under § 101(a)(2) if it is reasonable and rationally related to legitimate interests recognized by the statute, including protecting internal self-government from undue external influence.
- The statutory protections in § 101(a)(2) are not coextensive with the First Amendment; courts evaluate union rules under the LMRDA’s reasonableness standard rather than applying the more demanding constitutional scrutiny used for government regulation of political elections.

## Conclusion

The Court upheld the union’s ban on nonmember campaign contributions as a reasonable internal regulation under LMRDA § 101(a)(2), holding that the statute does not import full First Amendment campaign-finance standards and permits union rules that reasonably protect union self-governance even if they burden some election-related speech and organizing.


United Steelworkers of Am. v. Sadlowski, 457 U.S. 102 (1982)