Toyota Landscaping Co. v. Southern California District Council of Laborers

Toyota Landscaping Company, Inc. (“Toyota Landscaping”) appeals the district court’s judgment in favor of the Southern California District Council of Laborers and three laborers local unions (collectively referred to as “Laborers Union”). Toyota Landscaping contended that a subcontracting clause in the Laborers Union’s collective bargaining agreement with associations of Southern California general contractors resulted from a conspiracy with Toyota Landscaping’s competitors, in violation of the Sherman Antitrust Act, 16 U.S.C. §§ 1 , 2. A jury rendered a verdict adverse to Toyota Landscaping on its antitrust claim. Toyota Landscaping also contended that the subcontracting clause violated the Labor Management Relations Act (“LMRA”), 29 U.S.C. § 186 . The court, sitting without a jury, ruled adversely to Toyota Landscaping on its LMRA claim. Toyota Landscaping appeals only the ruling on its LMRA claim. We have jurisdiction under 28 U.S.C. § 1291 . We affirm the district court’s ruling that Toyota Landscaping lacked standing to assert the LMRA claim.

*116 BACKGROUND

In 1986, Toyota Landscaping provided landscape services for construction projects. Laborers Union was signatory to a…