United Mine Workers of America Health & Retirement Funds v. Robinson

PETITIONER: United Mine Workers of America Health & Retirement Funds
RESPONDENT: Gracie Robinson and Juanita Hager, et al.
LOCATION: Offices of the Trustees

DOCKET NO.: 81-61
DECIDED BY: Burger Court (1981-1986)
LOWER COURT: United States Court of Appeals for the District of Columbia Circuit

CITATION: 455 US 562 (1982)
ARGUED: Jan 13, 1982
DECIDED: Mar 08, 1982
GRANTED: Oct 05, 1981

ADVOCATES:
E. Calvin Golumbic - on behalf of the Petitioners
Larry Franklin Sword - on behalf of the Respondents

Facts of the case

A new collective bargaining agreement increased health benefits for widows of coal miners who were receiving pensions when they died. The agreement did not increase benefits for widows of coal miners who were still working at the time they died, although they were eligible for pensions. These health benefits were paid out of a trust fund financed by the operators. Gracie Robinson and Juanita Hager brought this class action on behalf of all similarly situated widows. They alleged that requiring the worker to be receiving a pension at the time of death to qualify for increased health benefits bore no relation to the purpose of the trust. The district court denied relief, but the U.S. Court of Appeals for the District of Columbia Circuit reversed. The Court of Appeals held that the collective bargaining agreement failed to meet the reasonable standard set out in the Labor Management Relations Act (LMRA). The LMRA requires pension trusts to be maintained “for the sole and exclusive benefit of employees…and their families”.

Question

Did the Court of Appeals have authority to review the terms of a collective bargaining agreement under a reasonableness standard?

Media for United Mine Workers of America Health & Retirement Funds v. Robinson

Audio Transcription for Oral Argument - January 13, 1982 in United Mine Workers of America Health & Retirement Funds v. Robinson

Warren E. Burger:

We will hear arguments next in United Mine Workers against Robinson.

Mr. Golumbic, I think you may proceed when you are ready.

Justice White will join us very shortly.

E. Calvin Golumbic:

Mr. Chief Justice, may it please the Court, the court of appeals in this case decided that the substantive terms of the collective bargaining agreement embodied in an employee benefit trust was subject to review by federal courts for reasonableness, under the sole and exclusive benefit provision of Section 302(c)(5) of the Taft-Hartley Act.

This decision, we submit, is inconsistent with the intent of Congress, as revealed by the national labor laws.

The national labor laws were based on private bargaining with governmental supervision alone.

Congress was not concerned with the substantive terms upon which parties agreed.

Accordingly, this Court has on numerous occasions rejected attempts by federal courts to substitute their own judgment for that of the collective bargaining parties.

Of course, collective bargaining agreements and collective bargaining parties are not subject to unqualified authority.

A collective bargaining agreement may be reviewed and revised if it violates the Constitution or federal law, but absent such a violation, the collective bargaining procedure should not be interrupted, so long as that process was conducted in good faith.

The record before the court of appeals in this case clearly reflected that the agreement to exclude the widows and respondent's class was the subject of prolonged, intense, and informed bargaining.

In fact, the court below acknowledged that the--

Warren E. Burger:

But it was bargaining, wasn't it?

E. Calvin Golumbic:

--Excuse me?

Warren E. Burger:

It was bargaining?

E. Calvin Golumbic:

The issue was bargained from the day the bargaining commenced until, indeed, the parties decided to agree in order to agree to a final bargaining agreement in order to avoid a strike.

Given the fact, given the fact that the agreement in this case was the result of good faith collective bargaining, the court should have restrained, or refrained from reviewing it.

Instead, the court decided to become a party to the negotiations and impose its own view of a desirable settlement.

The court justifies its intervention in this case by asserting that the eligibility rules of an employee benefit trust established through collective bargaining are subject to review for reasonableness pursuant to the sole and exclusive benefit provision in Section 302(c)(5) of the Taft-Hartley Act.

The court, in support of that proposition, the court relies on a series of cases decided by the D. C. Circuit which involve acts undertaken by collective bargaining parties... excuse me, which involve acts undertaken not by collective bargaining parties, but by trustees of employee benefit trusts.

These cases do not support the proposition that authority to review eligibility rules for reasonableness emanates from Section 302(c)(5).

William H. Rehnquist:

Do you think those cases are correctly decided?

E. Calvin Golumbic:

I think those cases are correctly decided, Justice Rehnquist, insofar... insofar as they rest on the jurisdictional basis of a court of equity to review the discretionary acts of trustees, and insofar as they decided that in those particular instances, in those cases the trustees had abused their discretion.

William H. Rehnquist:

Properly decided under 302(c)(5)?

E. Calvin Golumbic:

The cases were decided on the authority of a court of equity to review the discretionary acts of trustees, and in no instance did the cases rest on a jurisdictional basis under the Taft-Hartley Act, such as Section 302(c) or 302(e).

These cases demonstrate that the authority to review in each of the cases rested on the broad authority of a court of equity to review the discretionary acts of Taft-Hartley trustees.

Other courts also decided that they have authority to review the discretionary acts of Taft-Hartley trustees, and these courts based their authority on Section 302(e), which in their view authorized the review of employee benefit trusts for a structural violation of Section 302(c)(5).

The scope for review under the structural violation doctrine remains unsettled.

The Third Circuit has adopted a rather broad scope of review under the doctrine.

The First Circuit has limited review under the doctrine to ascertaining whether employee benefit trusts conform to the express requirements of Section 302(c)(5).