Lagana v. International Brotherhood of Electrical Workers—Local 1274

Summary

The Rhode Island Supreme Court held that a private-sector employee’s unfair-representation claim against a union was governed by the federal six-month statute of limitations under 29 U.S.C. § 160(b). Because the claim involved interpretation of a collective-bargaining agreement, it was preempted under § 301 of the Labor Management Relations Act. The court distinguished its prior decision applying Rhode Island’s three-year limitations period to a municipal employee’s claim and affirmed summary judgment for the union.

Holdings

1. A private-sector employee's unfair-representation claim against a union is governed by the federal six-month statute of limitations when the dispute concerns interpretation of a collective-bargaining agreement and is therefore preempted under § 301 of the Labor Management Relations Act.
2. McDonald's application of Rhode Island's three-year statute of limitations is limited to unfair-representation actions brought by municipal or state employees against public-sector unions.

Questions Presented

1. Whether a private-sector employee's unfair-representation action against a union, arising from a grievance requiring interpretation of a collective-bargaining agreement, is governed by the federal six-month statute of limitations in 29 U.S.C. § 160(b).
2. Whether McDonald v. Rhode Island General Council required application of Rhode Island's three-year statute of limitations to the claim.

Disposition

affirmed