International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America v. Brock

PETITIONER: International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America
RESPONDENT: Brock
LOCATION: Rhode Island District Court

DOCKET NO.: 84-1777
DECIDED BY: Burger Court (1981-1986)
LOWER COURT: United States Court of Appeals for the District of Columbia Circuit

CITATION: 477 US 274 (1986)
ARGUED: Mar 25, 1986
DECIDED: Jun 25, 1986

ADVOCATES:
Carolyn B. Kuhl - on behalf of the respondent
Marsha S. Berzon - on behalf of the petitioners

Facts of the case

Question

Media for International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America v. Brock

Audio Transcription for Oral Argument - March 25, 1986 in International Union, United Automobile, Aerospace, and Agricultural Implement Workers of America v. Brock

Warren E. Burger:

We will hear arguments next in International Union v. Brock.

Ms. Berzon, you may proceed whenever you are ready.

Marsha S. Berzon:

Thank you, Mr. Chief Justice, and may it please the Court:

In this case, the UAW sued on behalf of its members to overturn a directive issued by the Secretary of Labor that resulted in denying trade readjustment allowance, or TRA benefits, to thousands of UAW members.

The UAW requested the district court to decide a single federal question, whether the Secretary of Labor's interpretation of federal law was in error, and if so, to direct the Secretary through his agents to correct that error by reconsidering under a proper standard claims denied under the invalid directive.

The district court agreed with us that the Secretary's directive in facted violated federal law, and that thousands of UAW members had in fact been illegally denied TRA benefits and granted the requested relief.

On appeal, however, the Court of Appeals did not reach the merits of this controversy, nor did it reach any number of procedural defenses raised by the government, some for the first time in the Court of Appeals.

Instead, the Court of Appeals decided the case on an issue that had never previously been raised, principally on this issue, and that is whether the UAW had standing to litigate this case at all.

It is this standing issue that we have brought to this Court on certiorari, principally, and that is before this Court today.

If, as we believe it must, this Court reverses on that issue and decides that the UAW may in fact serve as the collective voice of its members in this litigation, then the other procedural issues would be opened on remand in the Court of Appeals.

What this says is that the issue before this Court is considerably simpler than the government's brief might suggest.

There is a standing issue, and the remainder of the issues are procedural issues opened on remand in the Court of Appeals, as the government's brief--

William H. Rehnquist:

Well, Ms. Berzon, you are speaking generally of what you call procedural issues.

Is the question of whether this is a proper use of the declaratory judgment in this situation where Congress appears to have thought review should go through the state courts, is that what you call a procedural issue?

Marsha S. Berzon:

--No.

That issue which the government is willing to assume in this case, that is, that we do have subject matter jurisdiction--

William H. Rehnquist:

Well, I don't know how you define subject matter jurisdiction, but at any rate, address yourself to the question I asked you.

Marsha S. Berzon:

--I think I am, and that is whether in fact there is review under federal question jurisdiction of federal questions concerning Trade Act benefits, or whether the Trade Act itself requires that all such questions be decided in state court, and our answer to that question is that what the Secretary of Labor keeps asserting, that there is something in the Trade Act that requires that the questions be decided in state court, there is simply no such provision.

What the Trade Act says in Section 239(d) is that determinations with respect to eligibility for benefits are to be decided in the same manner and to the same extent as determinations under the state unemployment insurance law.

That language does not say that the review is to be in state court or under state law.

Instead, it sets up a comparative standard.

If you look at the relevant body of comparative law, that is, state unemployment insurance law, one finds a long line of cases in this Court and in the lower federal courts, and one would expect to find such cases, in which there is ordinary federal question jurisdiction to decide federal issues with respect to those benefits, and in fact, if there is any doubt about this, this Court decided in... a year before this statute was passed with respect to precisely parallel language in 5 USC Section 8502(d) in Christian v. The Department of Labor of New York that there was federal jurisdiction in that case to decide a federal question.

Consequently, Congress has not created an anomaly such as is suggested by the government and sent off to state court issues with respect to a purely federal benefit program where all the money is federal, the administrative money is federal, this set of law that governs this case is federal.

William H. Rehnquist:

Yet, it is clear that any individual applicant who wants these benefits has to go through the state system.

No federal court is--

Marsha S. Berzon:

That is true unless and until the applicant wishes to challenge a federal policy directive which would govern the--

William H. Rehnquist:

--Yes, but he still has to go, to get the money amount of benefits that the statute provides, he has to go through the state system, doesn't he?

Marsha S. Berzon:

--In this instance, the relief did, for reasons related both to the fact that the UAW was the plaintiff and I think took proper regard for the state system and for the administration of the district court, decide only the single federal question and remand all claims back to the administrative system.

But that's the same thing that would have happened had the case gone up in a state court, the state--

William H. Rehnquist:

Yes, but what you're saying is that these players can split off one issue in the question of whether they are determined to get benefits, all the other issues going through a state court, and have the federal court decide that by a declaratory judgment.