Anderson v. Local Union No. 3, International Brotherhood of Electrical Workers
This opinion addresses a declaratory judgment action brought by Madison Square Garden Center, Inc. and Madison Square Garden Corporation (collectively, "the Garden") against Local Union No. 3, International Brotherhood of Electrical Workers ("Local 3"). The Garden sought a declaration that they are not liable to Local 3 for contribution or indemnification concerning a judgment previously entered against Local 3 in antecedent civil rights litigation (Ingram v. Madison Square Garden Center, Inc. and Anderson v. Madison Square Garden Center, Inc.). In those prior actions, Local 3 was found liable for intentional discriminatory hiring practices under Title VII of the Civil Rights Act of 1964 and 42 U.S.C. § 1981. The Court, presided over by Judge Sand in the Southern District of New York, granted the Garden's motion for summary judgment. The decision ruled that federal law governs, precluding contribution and indemnification under Title VII based on Northwest Airlines, Inc. v. Transport Workers. Furthermore, even if contribution were theoretically available under § 1981, it would not lie for an intentional tortfeasor, and any such claim would be defeated by a release given to the Garden by the original plaintiffs. Indemnity was also denied on similar grounds, emphasizing that an intentional tortfeasor cannot escape liability for deliberate wrongdoing.