United States Fourth Circuit

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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



  • United States Fourth Circuit


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