Conley v. Gibson
355 U.S. 42 (1957)
- Plaintiffs work in the Houston Freight Yard of the Texas and New Orleans Railroad.
- Defendants are the Brotherhood of Railway and Steamship Clerks (union), the Local Union 28, and their officers.
- There was contract between the Union and Railroad that gave union members certain protections from discharge and demotion
- In May 1954 the Railroad pretended to abolish 45 jobs held by African Americans, firing or demoting all 45.
- The Union refused to defend them and the jobs were later filled by whites (union members?). The few AA that remained were all demoted.
- Trial court: judgment for defendants
- Circuit court affirms
Reversed and remanded
Contentions of parties:
- the Union failed to protect AA members from discrimination
- The protection given to AA was not equal to that given to white employees
- Union violated plaintiff’s rights under Railway Labor Act (RLA).
- Failed to state a claim upon which relief can be given
- Not enough factual evidence in complaint to support allegations of discrimination
Whether plaintiffs failed to state a claim by not providing enough specific evidence in their complaint against the defendants for violating the RLA’s provision against discrimination.
Plaintiffs did not fail to state a claim by not providing enough specific evidence in their complaint against the defendants for violating the RLA’s provision against discrimination because it does not appear beyond doubt that the plaintiff can prove nothing to support his claim that he is entitled to relief.
A complaint cannot be dismissed for failure to state a claim “unless it appears beyond doubt that the plaintiff can prove no set of facts in support of the claim that entitle him to relief.”
Rule of Law:
Railway Labor Act (RLA).
Rule 8. General Rules of Pleading
(a) Claims for Relief.
A pleading which sets forth a claim for relief, whether an original claim, counterclaim, cross-claim, or third-party claim, shall contain (1) a short and plain statement of the grounds upon which the court’s jurisdiction depends, unless the court already has jurisdiction and the claim needs no new grounds of jurisdiction to support it, (2) a short and plain statement of the claim showing that the pleader is entitled to relief, and (3) a demand for judgment for the relief the pleader seeks. Relief in the alternative or of several different types may be demanded.
Even though a union can negotiate an agreement with an employer that is fair to all, the administration of this agreement can be discriminatory if it has the tacit or active consent of the union.
Reversed and remanded.