Los Angeles, California — The Ninth Circuit Court has recently upheld a lower court’s dismissal of a collective lawsuit brought by members of SAG-AFTRA against their union, citing time constraints and legal preemption of claims. The case stemmed from allegations that SAG-AFTRA breached its fair representation duty by negotiating a return-to-work agreement that permitted studio and producer partners to mandate COVID-19 vaccinations, which some union members opposed for various reasons.
The U.S. District Court for the Central District of California had previously dismissed the members’ claims on two significant grounds. First, it ruled that the Labor Management Relations Act (LMRA) preempted the state-law claims put forth by the plaintiffs, which included allegations of breach of contract, breach of fiduciary duty, negligence, and emotional distress. The court found that the interpretation of the relevant agreement was essential to resolving the dispute, thus activating the LMRA’s protective provisions.
Moreover, regarding the claim of unfair representation, the District Court noted that the plaintiffs had missed the statute of limitations for bringing such a claim. The court specifically addressed and dismissed the plaintiffs’ assertion that the SAG-AFTRA strike of 2023 could extend this limitations period, reasoning that the work stoppage did not prevent members from recognizing their alleged grievances stemming from SAG-AFTRA’s negotiation strategies during the COVID-19 pandemic.
On appeal, the Ninth Circuit echoed the District Court’s conclusions, affirming the dismissal of the lawsuit and reinforcing the reasoning behind it.
This unpublished ruling may not serve as a binding precedent, yet it emphasizes the need for unions and employers to navigate vaccination mandates and other contentious elements of bargaining agreements carefully. Such disputes continue to be affected by LMRA preemption, despite the passionate responses these issues can invoke among members.
The legal landscape surrounding labor relations, especially during the pandemic, remains complicated and fraught with challenges, necessitating close scrutiny of all union actions by members.
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