Associated General Contractors v. California State Council Of Carpenters

459 U.S. 519 (1983)

Purchase the Printed Copy at bsmsphd.com

Nature of the Case

To access this section all you need to do is click here and register.

Facts

Ps are affiliated with the United Brotherhood of Carpenters and Joiners of America, AFL-CIO. Ps represent more than 50,000 individuals employed by Ds in the carpentry, drywall, piledriving, and related industries throughout the State of California. This case arises out of a dispute between parties to a multi-employer collective-bargaining agreement. Ps alleged the D coerced its members and third parties to do business with nonunion firms. Ps claim that this coercion affected unionized firms and restrained the business activities of Ps. P and D have been parties to collective-bargaining agreements governing the terms and conditions of employment in construction-related industries in California for over 25 years. The wages and other benefits paid pursuant to these agreements amount to more than $750 million per year. P alleged that Ds conspired to abrogate and weaken the collective-bargaining relationship between Ps and the signatory employers. P alleged that Ds goal was 'to weaken, destroy, and restrain the trade of certain contractors,' who were either members of P or memorandum contractors who had signed agreements with P; and second, to restrain 'the free exercise of the business activities of Ps and each of them.' The District Court dismissed the complaint, including the federal antitrust claim; the complaint alleged 'a rather vague, general conspiracy,' and that the allegations 'appear typical of disputes a union might have with an employer,' which in the normal course are resolved by grievance and arbitration or by the NLRB. P appealed. The majority of the Court of Appeals adopted a construction of the amended complaint which is somewhat broader than the allegations in the pleading itself. It held (1) that a Sherman Act violation -- a group boycott -- had been alleged; (2) that Ds' conduct was not within the antitrust exemption for labor activities; and (3) that Ps had standing to recover damages for the injury to their own business activities occasioned by the defendants' 'industry-wide boycott against all subcontractors with whom the Unions had signed agreements . . . .' The injury to Ps was a foreseeable consequence of the antitrust violation, and that injury was specifically intended by Ds. The Supreme Court granted certiorari