Motion Picture & Videotape Editors Guild, Local 776 v. International Sound Technicians, Local 695

Local 776 filed a complaint against Local 695 alleging breach of contract, interference with prospective business advantage, and libel and/or slander. Thereafter, Local 695 filed a counterclaim which, after two amendments, was the subject of a summary judgment motion. The district court granted the motion and Local 695 appeals. The district court based its decision on the failure of Local 695 to exhaust its internal remedies. We have jurisdiction pursuant to 28 U.S.C. § 1291 and the district court’s certification under Rule 54(b), Fed.R.Civ.P. We affirm, but on the ground that we decline to interfere with internal union affairs.

FACTS

This case arises out of an intraunion dispute among three local unions, Locals 695, 659 and 776, and their parent body, the International Alliance of Theatrical Stage Employees (IATSE or Alliance). In October 1973, Local 695 and Local 659 entered into a written jurisdictional agreement (the Agreement) recognizing that a person working as a “Technical Director” belonged within Local 695 and one working as a “Video Controller” belonged within Local 659. The execution of the Agreement was contingent upon approval by the International President because…