United Steelworkers of America v. Sadlowski
United States Supreme Court
457 U.S. 102 (1982)
- Written by Tammy Boggs, JD
Facts
The United Steelworkers of America (the union) was a labor organization with 1.3 million members, and it conducted elections for top union officers every four years. In the last election, two candidates ran for president: Edward Sadlowski, who received most of his funding from nonmember sources, and Lloyd McBride, who received most of his funding from union sources. McBride, who was supported by the incumbent union leadership, defeated Sadlowski, 57 to 43 percent. Before and after the election, the union debated the desirability of outsider campaign contributions and ultimately adopted a rule prohibiting campaign contributions by nonmembers (the “outsider rule”). Sadlowski and a few other individuals (plaintiffs) filed suit against the union in district court, challenging the validity of the outsider rule. The district court ruled in favor of Sadlowski, and the court of appeals affirmed, relying principally on union members’ protected rights of speech and assembly under the Labor-Management Reporting and Disclosure Act (LMRDA). The matter came before the Supreme Court.
Rule of Law
Issue
Holding and Reasoning (Marshall, J.)
Dissent (White, J.)
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