Milk Drivers and Dairy Employees Union, Teamsters Local 302 v. Craig Vevoda, Kenneth Chamness and Mark Sottana

This is an action by a union to collect fines levied against three of its members who violated the union’s bylaws by working behind a picket line during a strike. The district court had jurisdiction pursuant to section 301 of the National Labor Relations Act (NLRA), 29 U.S.C. § 185 .

The district court granted summary judgment for the defendants. It held that although the defendants had joined the union and had accepted all the burdens and benefits of membership until the time that they crossed the picket lines, they were nevertheless not bound by the contractual provisions applicable to union members. Defendants argued they had been fraudulently induced to join the union. They were told that, pursuant to a valid union security provision in the collective bargaining agreement, they had to become union members as a condition of employment, and they were not told that under recent case law, the membership requirements could be satisfied by merely paying dues. The district court concluded that they had not “knowingly or voluntarily” become members of the union. Milk Drivers & Dairy Employees Union v. Vevoda, 587 F.Supp. 483, 484 (N.D.Cal.1984). We reverse.

The facts are…