St. Clair v. Local Union No. 515 of the International Brotherhood of Teamsters’s Empirical Analysis
422 F.2d 128 · 1969
Citation profile
47 federal appellate · 3 district · 2 state decisions
How this case has been cited
Cited by 81 later decisions (2 by the Supreme Court) — most recently March 2019 · most notably International Brotherhood of Electrical Workers v. Foust (1979), Bowen v. United States Postal Service (1983)
47 federal appellate · 3 district · 2 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on United Steelworkers of America v. Enterprise Wheel and Car Corp · Vaca v. Sipes · Brady v. Trans World Airlines, Inc. · National Labor Relations Board v. Miranda Fuel Co., Inc., National Labor Relations Board v. Local 553, International Brotherhood of Teamsters, Chauffeurs, Warehousemen and Helpers of America
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 81 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“As the jury found, the union did not procure plaintiffs discharge. It was the decision of the employer (although the District Court seems not to have decided whether the company’s act was wrongful). .. The calculation of who caused which damages may present serious practical problems, but the Supreme Court has strongly implied that in cases like this, involving a discharge and an alleged failure by the union to take all available steps to remedy the employee’s complaint, the increment of damages caused by the union’s breach of the duty is virtually de minimus. “(A)ll or almost all of Owens’ (the employee’s) damages would still be attributable to his allegedly wrongful discharge by Swift (the company).” Vaca v. Sipes, 386 U.S. at 198 , 87 S.Ct. at 921 .”
2 later decisions quote this exact passage · from the majority“The governing principle, then, is to apportion liability between the employer and the union according to the damage caused by the fault of each. Thus, damages attributable solely to the employer’s breach of contract should not be charged to the union, but increases if any in those damages caused by the union’s refusal to process the grievance should not be charged to the employer. In this case, even if the Union had breached its duty, all or almost all of Owens’ damages would still be attributable to his allegedly wrongful discharge by Swift. For these reasons, even if the Union here had properly been found liable for a breach of duty, it is clear that the damage award was improper.”
1 later decision quote this exact passage · from the majority“[D]amages which do not arise naturally from a breach of the contract, or which are not within the reasonable contemplation of the parties, are not recoverable. "). Put another way, damages will not be awarded unless they reasonably should have been "contemplated by the parties as being at the heart of the contract.”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.