Rosario v. Local 1106 Transport Works of America
Plaintiff Louis Rosario sued his former employer, Transervice Lease Corporation, and his union, Transport Workers of America, Local 1106, alleging wrongful termination and inadequate union representation under the LMRA. Rosario's employment was terminated after he was accused of falsifying documents related to a vehicle repair. His union, Local 1106, failed to file for arbitration within the required 45-day period, leading an arbitrator to deem the grievance non-arbitrable in December 2010. Rosario filed his complaint in January 2013, more than two years after the arbitration denial. The Court granted Transervice's motion to dismiss, finding Rosario's hybrid § 301 LMRA claim time-barred by the six-month statute of limitations. The Court also dismissed the federal claim against Local 1106 sua sponte and declined supplemental jurisdiction over Rosario's state-law negligence claim against the union, dismissing it without prejudice.