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Media Alerts - Eddie McBride; Leonard Riley, Jr.; Eddie Knight; Charles S. Miller-Bey v. International Longshoremen's Association - Thir
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February 24, 2015
  Eddie McBride; Leonard Riley, Jr.; Eddie Knight; Charles S. Miller-Bey v. International Longshoremen's Association - Thir
Headline: Third Circuit Court of Appeals rules a party suing under the Labor-Management Relations Act does not have to win monetary damages to be a prevailing party and motive of the lawsuit does not matter in determining whether the lawsuit serves a common benefit for the members of the union.

Area of Law: Prevailing Party under the Labor-Management Relations Act.

Issues Presented: Whether a party can be a prevailing party under the Labor-Management Relations At if the party does not win any monetary damages.

Brief Summary: Eddie Knight ("Knight") brought an action against the International Longshoremen's Association ("the Union") based on a hearing where the Union decided to discipline Knight. Knight claimed the Union had violated certain rights, and eventually the District Court ordered the Union to change certain procedures. After the second hearing, Knight sued for damages, which were denied by the District Court and Third Circuit Court of Appeals. The District Court eventually awarded Knight attorney's fees and costs in excess of $200,000, which the Union appeals in this lawsuit.

The Union claimed Knight was not eligible for attorney's fees as a prevailing party under the Labor-Management Relations Act because he did not win any monetary damages. The Third Circuit disagreed and reasoned that Knight had prevailed in the earlier proceedings, which required the Union to change certain procedures. The Court further explained that Knight's motive for bringing the lawsuit was immaterial in determining whether the lawsuit conferred a common benefit to all union members.

Significance (if any):

Extended Summary: Eddie Knight ("Knight") brought an action against the International Longshoremen's Association ("the Union") after the Union concluded Knight committed three violations of the Union's constitution. Knight claimed the Union violated his freedom of speech, wrongly disallowed recording of the disciplinary hearing, had a biased union member serve on the board that adjudicated the dispute against Knight, and failed to give proper notice to union members about the Labor-Management Relations Act ("the Act"). After several years of litigation, the district court ordered the Union to amend its constitution and further ordered it to provide Knight with a new hearing before an impartial tribunal and to allow Knight to record the hearing. In the second hearing, the impartial tribunal sided with the Union. Knight appealed the judgment to the District Court and sought compensatory and punitive damages, along with attorney's fees and costs. The District Court did not award damages even though it ruled for Knight, but it did grant his request for attorney's fees. The Third Circuit then overturned the District Court's decision regarding liability and decided Knight was not entitled to any damages, but did not reach the issue of Knight's entitlement to fees. After remand, the District Court awarded Knight attorney's fees, costs, and post-judgment interest. The Union appealed the grant of fees and costs under the theory that Knight was no longer a prevailing party under the Act.

The Third Circuit first determined the District Court had jurisdiction to enter an award for fees and costs as the prior remands from the Third Circuit had not addressed the issues. As to Knight's status, the Court explained that a party need not receive monetary damages to be a prevailing party as an award of performance or injunction (here the Union was ordered to modify its procedures) was sufficient for a party to be able to have a common benefit for all union members. Further, the Third Circuit determined attorney's fees could be granted as an interim award, although the Court concluded that the judgment at issue was a final judgment. Lastly, the Third Circuit determined Knight's lawsuit conferred a common benefit to all union members as it led to changes in procedures that were significant. Finally, the Court explained that Knight's motive for bringing the lawsuit did not affect whether the benefit was given to the whole union membership.

To read the full opinion, please visit
http://www2.ca3.uscourts.gov/opinarch/134260p.pdf

Panel (if known): Fuentes, Greenaway, Jr., and Nygaard, Circuit Judges

Argument Date: June 23, 2014

Argument Location: Philadelphia, PA

Date of Issued Opinion: February 19, 2015

Docket Number: No. 13-4260

Decided: Affirmed

Case Alert Author: Ilya Gomelsky

Counsel: Stephen B. Potter, Esq. and John P. Sheridan, Esq. for Appellant; Michael J. Goldberg, Esq. and Perry F. Goldlust, Esq. for Appellees

Author of Opinion: Nygaard, Circuit Judge

Circuit: Third Circuit

Case Alert Circuit Supervisor: Professor Mary E. Levy

    Posted By: Susan DeJarnatt @ 02/24/2015 10:44 AM     3rd Circuit  

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