Eli Bergida

Document Type

Case Summary

Publication Date

3-2021

Case Synopsis

This case involves a union dues dispute between local (CCEA), state (NSEA), and national (NEA) unions. The district court ruled in favor of CCEA.

On appeal, NSEA and NEA argued that they were entitled to summary judgment. First the union dues contract remained effective and bound CCEA to transmit its dues. Second, CCEA was still obligated to submit the dues under the NSEA and NEA bylaws. Third, NSEA and NEA are entitled to the disputed dues under theories of unjust enrichment or conversion. Lastly, the district court improperly considered CCEA’s refund offer to the teachers in granting summary judgment for the fraud claims.

The Court affirmed the district court’s judgment. First, NEA’s bylaws expressly reserved the local union’s obligation to submit dues for a separate contract. Second, CCEA terminated that contract and ended its obligation to submit dues. Third, because CCEA was not obligated to submit the dues—which they placed in an escrow account pending litigation—they did not commit unjust enrichment or conversion. Lastly, while an offer to pay a disputed sum does not clear a fraud claim, the appellants did not produce sufficient evidence supporting that CCEA knowingly made a false statement.

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