Services Employees International Union v. National Union of Healthcare Workers

OPINION

TALLMAN, Circuit Judge:

This appeal presents a classic union power struggle. We must resolve whether § 501 of the Labor Management Reporting and Disclosure Act creates a fiduciary duty to the union as an organization, not merely the union’s rank-and-file members. We hold that it does.

The defendants, who by jury verdict 1 were determined to be rogue local union officials who diverted union resources in an attempt to establish a new competing local union, breached this duty. The international union’s executive committee had decided to consolidate all of its California unionized long-term…