Allen v. Allied Plant Maintenance Company of Tennessee
Plaintiff Allen sued Allied Plant Maintenance Company, the International Union of Operating Engineers (IUOE), and Local 912 of the IUOE following his discharge in July 1984. Allen alleged a conspiracy among the defendants, leading to violations of federal labor laws, including the National Labor Relations Act (NLRA), Labor Management Reporting and Disclosure Act (LMRDA), and the duty of fair representation (DFR) under the Labor Management Relations Act (LMRA), as well as a state claim for breach of employment contract. Chief Judge Wiseman granted summary judgment to the defendants on all claims except the DFR claim. The Court dismissed Allen's civil rights claim under 42 U.S.C. § 1985(2) due to a lack of class-based discriminatory animus and an insufficient nexus to a federal court proceeding, and found the NLRA claims preempted by the NLRB's exclusive jurisdiction. The LMRDA claim was dismissed as it did not infringe upon Allen's rights as a union member. The judge denied the defendants' motion to strike Allen's jury demand for the DFR claim but granted the motion to strike his request for punitive damages.