United States Fourth Circuit
Trail v. Local 2850 UAW, 12-1632
Dismissal of plaintiff's claim alleging that defendant-union officials violated the Labor-Management Reporting and Disclosure Act (Act) by retaliating against her for reporting their supposed misconduct to the regional office is affirmed, where: 1) plaintiff did not speak on a matter of union concern when she reported the alleged pornography incident to Region 8; and thus, 2) the district court thus did not err in holding that she failed to state a claim under the Act.
Appellate Information
- Decided 03/21/2013
- Published 03/21/2013
Judges
Court
- United States Fourth Circuit