R.M. Perlman Inc. v. New York Coat, Suit, Dresses, Rainwear & Allied Workers' Union Local 89-22-1
This case involves R.M. Perlman, d/b/a Rebecca Moses Collection (RMC), a garment industry employer, suing two labor unions, Local 89-22-1 and the International Ladies Garment Workers’ Union. The suit stemmed from picketing aimed at compelling RMC to enter into a Hazantown Agreement, which RMC alleged involved violence and caused substantial losses. The amended complaint included federal claims under the National Labor Relations Act and state law claims such as prima facie tort, intentional interference with contractual relations, and defamation. The defendants moved to dismiss the state law claims, arguing federal preemption and RMC's failure to meet New York's specific pleading requirements for actions against unincorporated associations. The court found the state law claims were not preempted due to allegations of violent picketing, aligning with exceptions to federal preemption. However, the court ultimately granted the dismissal of the state law claims (counts two through seven) because RMC failed to allege that every single union member authorized or ratified the violent acts, as required by the New York Court of Appeals decision in Martin v. Curran. Additionally, the individual defendants Byer and Mazur were dismissed because the remaining federal claim under the Labor-Management Relations Act does not allow for individual liability. A motion to dismiss Rebecca Moses as a plaintiff was denied, pending further evidence on her standing. Plaintiffs were granted thirty days to replead the dismissed state law claims.