Austin v. Calhoon
Anderson Austin, a long-standing member of The National Marine Engineer’s Beneficial Association (MEBA), filed a suit against Jesse M. Calhoon, Chairman of the MEBA Pension Trust, seeking a disability pension. Austin, who had suffered from a duodenal ulcer since 1961, applied for the pension in 1967, but his application was rejected by the Board of Trustees in 1971 based on a medical judgment. Calhoon moved to dismiss the case, arguing that the court lacked subject matter jurisdiction under Section 301 of the Labor Management Relations Act. The court granted the motion to dismiss, concluding that Austin's claim involved a uniquely private medical judgment rather than an issue of contract interpretation or union interests, thus falling outside the scope of Section 301 jurisdiction.