Herman v. Springfield Massachusetts Area

BOUDIN, Circuit Judge.

This appeal involves the validity of an eligibility requirement imposed by a union on candidates for officer positions. The union, which is a Springfield, Massachusetts local of the American Postal Workers Union, holds officer elections once every three years. Under its constitution, a candidate for office must have been a member of the union for at least one year (two, if running for president) and — this is the disputed provision — must have attended at least three of the local’s regular monthly meetings in the twelve month period before the meeting at which…