Amalgamated Transit Union, Local 1300 and David A. McClure v. William T. Lovelace, Jr.

Summary

The Maryland Court of Appeals held that a union member seeking monetary damages for defamation was not required to exhaust internal union remedies when those remedies could not award monetary damages. The court affirmed the Court of Special Appeals and concluded that the union’s motions to dismiss, which relied on materials outside the pleadings, were properly treated as motions for summary judgment.

Holdings

1. When a union member claims that the union and a fellow union member are liable for defamation and seeks monetary damages, internal union remedies that do not provide monetary damages are inadequate, so the member is not required to exhaust them before filing suit.
2. The circuit court's consideration of the Local 1300 Constitution outside the pleadings required the motions to dismiss to be treated as motions for summary judgment under Maryland Rule 2-322(c).

Questions Presented

1. Whether a union member claiming defamation by the union and a fellow union member must exhaust internal union remedies before filing suit when those remedies do not provide the monetary damages sought.
2. Whether the circuit court properly treated the motions to dismiss as motions for summary judgment after considering the Local 1300 Constitution.

Disposition

affirmed