Boss v. International Brotherhood of Boilermakers, Iron Shipbuilders, Blacksmiths, Forgers & Helpers
In this class action, plaintiffs alleged that the International Brotherhood of Boilermakers, Iron Shipbuilders, Blacksmiths, Forgers and Helpers breached its duty of fair representation and collective bargaining agreements under the Labor Management Relations Act. Plaintiffs, who are New York residents qualified as 'boilermakers', claimed they were denied employment due to actions of local unions acting as agents of the International. The central issue was whether the International could be held vicariously liable for the local unions' acts based on agency principles. The court reviewed federal case law, particularly emphasizing the 'control' and 'autonomy' of local unions, citing Carbon Fuel Co. v. United Mine Workers. Finding no evidence that the International instigated or ratified the complained-of acts, and noting the locals retained autonomy despite the International being the sole signatory, the court granted the defendant's motion for summary judgment and denied the plaintiffs' motion for class certification.