Crocco v. Local 333, United Marine Division, International Longshoremen's Ass'n
Augustine Crocco, a former President of Local 1294, International Longshoremen’s Association, AFL-CIO, sued several labor unions under the Labor-Management Reporting and Disclosure Act (LMRDA), alleging he was improperly disciplined. Crocco claimed that an unfair disciplinary hearing and a recommendation for his removal from office and disqualification from future elections led to his defeat in a subsequent election, even though no formal discipline was imposed. The defendants moved for summary judgment, arguing no actual 'discipline' occurred under LMRDA § 101(a)(5). The court examined the definition of 'discipline' and precedent but found no evidence of bad faith prosecution by the unions. Ultimately, the federal court ruled it lacked subject matter jurisdiction over the LMRDA claims because federal courts have exclusive jurisdiction, and thus the state court from which the case was removed had no original jurisdiction. The LMRDA claims were dismissed, and the remaining state law claims were remanded to the Supreme Court of New York for Rensselaer County.