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Washington Teachers Union Executive Board
Reply to plaintiff’s memorandum of law in opposition to the motion to dismiss the claims against defendant Members of the Executive Board
April 11, 2003




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NATHAN A. SAUNDERS, Plaintiff, v. ESTHER HANKERSON, et al., Defendants, Civ. Action No. 02-2536 (EGS)

AMERICAN FEDERATION OF TEACHERS, AFL-CIO, et al., Plaintiffs, v. BARBARA BULLOCK, et al., Defendants, Civ. Action No. 03-79 (EGS)


In their Memorandum of Points and Authorities in Support of their Motion to Dismiss ("Exec. Bd. Mem."), the Defendant Executive Board members claimed: (1) that Plaintiff failed to establish subject matter jurisdiction on several bases, including on the grounds that the Washington Teachers Union ("WTU") is a public employees union; (2) Plaintiff failed to state a claim upon which relief can be granted; and (3) Plaintiff lacks standing to assert claims under the Labor-Management Reporting and Disclosure Act ("LMRDA"), 29 U.S. C. §§ 401-531. With the exception of the claim premised on the grounds that the WTU is a public employees union, which Defendants waive, Plaintiff has not demonstrated that the legal and jurisdictional predicates have been met, nor will he be able to based upon the pleadings and record before this Court.

In the interest of brevity, citations will, where possible, be made to arguments of law already before this Court in these Defendants' and the American Federation of Teachers' ("AFT") Memoranda of Points and Authorities in Support of their respective motions to dismiss. This reply will focus on the importance of the jurisdictional predicates, especially as applied to the facts as presented by the Plaintiff, and the reasons, therefore, why his Opposition fails to demonstrate that either this Court has subject matter jurisdiction, that he has any justifiable claim, or that he has standing.


Plaintiff Nathan Saunders purports to bring this claim on behalf of the members of the WTU under a variety of theories, but as to these Defendants, the relevant claim relates to an alleged "breach of fiduciary duty," pursuant to LMRDA, 16 U.S. C. § 501(b). This allegation is bottomed on the theory that the "Executive Board [members] . . . failed in their roles as fiduciaries and abandoned, for several successive years, their affirmative duties to oversee the WTU's activities," First Amended Complaint ("Am. Compl.") ¶3, because the Individual Defendants2 as to whom this alleged failure of oversight relates allegedly engaged in deplorable and illegal behavior. Id. 1. To state a claim, a plaintiff must tie each defendant both to a duty and its breach.3 The problem, as explained below, is that the Plaintiff has employed a scattershot approach by naming as Defendants any and every official and organization affiliated in some way with the WTU, including those who, like Defendant Executive Board members, are not charged with having been part of the alleged corruption and who did not have any authority to police or prevent it.

As a result of this "take no prisoners" approach, the Complaint fails in several important ways to meet the jurisdictional and prudential requirements necessary to proceed in court on an LMRDA § 501(b) claim:

  • The allegations against the Defendants do not relate back to the demand Plaintiff claims to have made4;
  • The allegations against the Executive Board Defendants, phrased in so general a manner, do not meet the requirements for showing "good cause"; and
  • Taken as absolutely true, the Complaint fails to state a claim under LMRDA § 501(b).

 These procedural prerequisites are more than mere technicalities, they are designed specifically to avoid the intermingling of internecine union political rivalries (as exist here, see AFT Mem. at 35-36) and the legal process.5 The predicates to bring a claim, none of which the Plaintiff met, include: 1) a demand to the union for a suit or accounting; 2) refusal; 3) a verified petition to a court; and 4) a demonstration of good cause. 29 U.S.C. § 501(b). The demand element is not a formality - a clear demand, invoking a clear-cut duty, stating a clear breach of that duty, and followed, if the predicate is to met, by a refusal to address the demand after a reasonable time are important guideposts for this Court in sorting out issues redressable under the LMRDA from the airing of political grievances relegated by law to the union ballot box. These required elements are addressed in detail below.


A. Plaintiff Did Not Make a Demand for a Suit at Law

Plaintiff attempts to avoid the specific strictures of § 501(b) and the ample, controlling case law directly holding that a demand for a suit is required. Particularly unpersuasive is the Plaintiff's attempt to brush off the direct authority from the District of Columbia Circuit that the demand must be for a suit at law. See Plaintiff's Memorandum in Opposition to the Motion to Dismiss the Claims Against Members of the Executive Board ("Pl.'s Mem. Op.") at 3-4. The directly relevant cases all hold that "Section 501(b) specifically requires that union members present a demand to sue and be refused before leave to bring a derivative suit may be granted."6 Hanahan v. Lucassen, 764 F. Supp. 194, 196 (D.D.C. 1991). Conversely, all but two of the cases cited in note 1 of Plaintiff's Opposition, as well as Sabolsky v. Budzanoski, 547 F.2d 249 (3d Cir. 1972), involved situations where, generally speaking: 1) the "bulldozer was at the door;" 2) there was thorough exhaustion of internal union remedies; or 3) both of these situations. See, e.g., id. at 1253 ("The letter of request addressed to President Budzanowski, although not a request of the officer to sue, did seek internal relief, and in the circumstances then existing, with a [potentially illegal] District election fast approaching, cannot be deemed insufficient."); Cefalo v. Moffett, 333 F. Supp. 1283 (finding jurisdiction under § 501(b) to enjoin an imminent merger vote when Plaintiff had previously "complained of wrongs" in unspecified manner).

Flaherty v. Warehouseman, Garage & Service Station Employees' Local Union No. 334, 574 F.2d 484 (9th Cir. 1978), actually helps the Defendants. In that case, the plaintiff, immediately in advance of a meeting at which a dues increase was to be discussed, "initiated a series of oral and written demands to be provided with the financial records of the local." Id. at 485. "These requests were not complied with and the plaintiff filed suit in Washington state court seeking, among other things, a declaration that the actions taken at the May 31st meeting, i.e., approval of the dues increase and the proposed expenditures, were void" Id. "The complaint contained no allegation that any request had been made of the defendants to take action to remedy the conduct complained of." Id. (emphasis added). In other words, the plaintiff made a demand to view records, but filed suit to challenge the validity of actions taken at the meeting. The court held this to be fatal to the § 501(b) claim:

Because section 501 (b) extends the jurisdiction of the federal courts, it is strictly construed. Among the conditions precedent to the filing of such a suit is the requirement that the plaintiff make a demand upon the labor organization or its officers to secure appropriate relief. An allegation of the futility of such a request will not suffice. Failure to allege that the required request has been made has been held to require denial of leave to file the complaint.

Id. at 487 (citations and internal quotation marks omitted). The demand made and relief sought must "line up" in the sense that a putative plaintiff must seek redress in court for the very thing demanded and refused.

Similar to the plaintiff's complaint in Flaherty, in Mr. Saunders' suit, the demand made and the relief sought do not "line up" as is required. Here, Mr. Saunders demanded information on, and a speedier and more comprehensive disbursement of, the errant dues deduction, but sued on the malfeasance of the Individual Defendants, and the other Defendants' alleged duties with respect to them. As in Flaherty, here, the demand made and legal challenge brought are ships passing in the night.7 No amount of post hac rationalizing can turn Plaintiff's dues protest to the WHU into a proper demand for a suit to recover in excess of five million dollars.

Even the case which the Plaintiff emphasizes, Adams Lundy v. Assn Professional Flight Attendants, 844 F.2d 245 (5th Cir. 1988), read for the proposition urged, i.e., that requests for actions by a union short of an explicit demand for a suit meets the requirements of § 501(b),8 shows that what courts have accepted as substitutes for an unequivocal demand to initiate suit is a detailed notice of the exact grounds for complaint. See id. at 250 n.20-22 (detailing grievances); see also Sabolsky v . Budzanoski, 457 F.2d 1245, 1251 (3d Cir. 1972) (making specific complaints directly related to issues in suit to the highest local and international official). Thus, even if this Court inclined to erode the demand requirement, it should, at least, hold that the demand be unequivocal, some formal process is employed (and exhausted), and the suit be directly related to the demand. This final "mirror image" requirement was not met here, and the Plaintiff's demand did not give adequate notice of the case as it has been brought.

Finally, there is a strong argument for making the demand requirement stringent. Solid legal and policy rationales support strict fidelity to the language of § 501(b), see Exec. Bd. Mem. at 6-7; AFT Mem. at 15-16, and although the law is remedial, designed to "protect union members," Adams-Lundy, 844 F.2d at 249, this requirement is jurisdictional and should be "strictly construed." O'Connor, 1985 WL 121, *1 (D.D.C 1985). At the most practical level, the reason for having a requirement that a potential plaintiff make a strong and clear demand is to insure that those against whom a breach of duty might be alleged are made aware of exactly what they are being asked to do, and so the union has an opportunity to employ its own corrective process while conserving judicial resources. Int'l Longshoremen's Assn v. Virginia Int'l Terminal, Inc., 932 F. Supp. 761 (E.D. Va. 1996). Having a demand that is clear, and which clearly implicates the duties of specific union officials that is apropos their constitutional role within the organization, also permits a court to distill the elements of duty, authority, and breach. These are important protections for union officers that were coupled with the right of action (carrying significant penalties) the LMRDA created.9 It is a fact of life in local union politics that charges are frequently levied, accusations often fly, and campaign rhetoric gets hot.l0 The requirement for an unequivocal demand allows for the conversion of that chaos into a case or controversy in the federal courts.

B. Defendants Did Not Refuse Any Demand, nor Did Plaintiff Seek Leave to File Suit in a Timely Manner

Not only must there be a demand, but the union must also refuse to meet the demand within a reasonable period of time. See Exec. Bd. Mem. at 7. In fact, as the Complaint shows, of the demands contained within the November 2002 letter, see Am. Comp. ¶¶40-42; Compl. Exh. 8.1, nearly all relief sought has been obtained.

The WTU Executive Board provided the information sought by Plaintiff "on or about January 6, 2003." Id. ¶52. To the extent that Plaintiff feels that all the concerns raised by the November 2002 letter were not addressed, the Union reasonably replied that as to certain financial matters there was an ongoing criminal investigation with which they presumably did not wish to interfere.'' Id. ¶51. Further, the AFT conducted a forensic audit into the WTU finances, id. ¶37, and initiated a lawsuit to recover wrongfully appropriated monies. Id. ¶55. Finally, Plaintiff and all members of the WTU received their wrongfully deducted dues, as requested. Id. ¶¶35-36. Indeed, dues refunds were already occurring even prior to the Plaintiff's November entreaties which he is now seeking to convert into a demand. See Compl., Ex. 8.1, at 2 (inquiring why dues refunds were "currently" being made from the next year's budget).

Just on the face of the Complaints and Exhibits, therefore, it is impossible to find the "refusal" required by § 501(b). What Plaintiff actually "demanded"12 was done by the WTU. On this record, even granting all reasonable inferences to the Plaintiff, there is no refusal on the Union's behalf. Rather, the record speaks of accommodation by the WTU of numerous and shifting requests of a Plaintiff who had all the earmarks of a political rival to the leadership then in charge of the Union. See AFT Mem. at 35-36.

Even if the demand and refusal elements were met, Plaintiff still failed to seek leave of the court and file a verified application before the AFT had already stepped in to sue in its own right on behalf of the members. See id. at 20-21. As a result, Plaintiff lacks standing to assert these claims. Id. at 20. Any fair reading of the Complaint and Exhibits, coupled with the Plaintiff's failure to state a demand, supra Part I, and the objections of the intervenors to representation by the Plaintiff, contrasted with the obvious seriousness and competence with which AFT is prosecuting its prior verified complaint, Plaintiff should be found to lack standing and the suit dismissed.

C. Plaintiffs Complaint Facially Lacks Good Cause, and His Failure to Meet Certain Conditions Prior to Bringing Suit Precludes a Finding of Good Cause

The good cause "provision protects union officials from harassment. The policies underlying § 501 to protect union members from improprieties by management and to protect union officials from harassment `must be balanced when deciding what is required to satisfy the requirement of a request for an accounting."' George v. Local Union No. 639, 1994 U.S. Dist. LEXIS 6042, *9 (D.D.C.), affd in part, vacated in part by 98 F.3d 1419 (D.C. Cir. 1996), (quoting Cowger v. Rohrbach, 868 F.2d 1064, 1066 (9th Cir. 1989)) (citation omitted). In the District of Columbia Circuit, this inquiry has two branches. One, "a district court may determine that a plaintiff has established good cause by looking at the verified complaint alone." George v. Local Union No. 639, 98 F.3d 1419, 1422 (D.C. Cir. 1996) (citing Horner v. Ferron, 362 F.2d 224, 228 (9th Cir. 1966), cert. denied, 385 U.S. 958 (1966)).13 Second, good cause can be challenged in a hearing, "[i]f the defendant can establish . . . that the action is barred by . . . failure to comply with a condition precedent to bringing suit, then the plaintiff will not have satisfied the good cause standard." Id. (citing Horner, 362 F.2d at 229).

Under the first branch, the Circuit Court has not provided any guidance for a court examining a verified complaint for good cause, other than it should not be subjected to a heightened pleading standard. Id. However, given that the Plaintiff bears the burden of establishing subject matter jurisdiction, see Exec. Bd. Mem. at 4, it would neither be appropriate for the Court to grant favorable inferences to the facts tending to establish good cause. While it is clear that the Court can undertake no "likelihood of success" analysis, see id., it seems fully appropriate that it be guided in its inquiry by some of the basic principles of the LMRDA, such as insuring that the complaint is not "harassing and vexatious" or "brought without merit." Supra, at n.13. In O'Connor v. Freyman, the court suggested factors which appear to also be of use, including taking "all the facts and circumstances into consideration in determining whether good cause has been shown, including the efforts made by plaintiffs to invoke internal remedies, plaintiffs' demand that the union sue, the refusal by the Board to sue, plaintiff s reasonable likelihood of success,14 as well as plaintiffs reasonable ground for belief in their claims." 1985 WL 121, at *13.

This appears to be a proper grounds for inquiry, which is a reasonable middle-ground between a heightened pleading standard and making inferences for the plaintiff on a issue effecting jurisdiction. Given the totality of the record, the disconnect between the apparent demands of the Plaintiff prior to initiating suit and in the original and amended complaints, the failure to make a coherent demand, the fact that no official union processes were employed (other than the motion on the limited issue of dues repayment), and the fact that the Union has step in and filed in court for relief and appears to be vigorously prosecuting that suit -- all of these factors should convince this Court that a finding of good cause is not warranted. Adding to these reasons, the zeitgeist of the Plaintiff's actions, for example the multitudinous lines of attack and palpable vitriol of some criticisms (see, e.g., Compl., Exh. 7, at 2 ("All are cautioned to be those who are excited to wear your oppressors [sic] shoes . . . .")), combined with the significant number of teachers seeking to intervene to oppose Plaintiff as a suitable class representative serve, again, to buttress Defendants' argument that this Court should find Plaintiff's complaint to be without good cause under this test.

This result is reinforced under the second branch of the George test, i.e., "[i]f the defendant can establish . . . that the action is barred by . . . failure to comply with a condition precedent to bringing suit," 98 F.3d at 1422, then it is beyond cavil that if no other matter is considered, that failure to make a legally sufficient demand, see supra Part 1, is just the sort of condition precedent the George court had in mind. For these reasons, Plaintiff has not and cannot demonstrate "good faith" under the law and the case should be dismissed.


For each of the foregoing reasons, Movants respectfully request that this Court issue an order granting its Motion to Dismiss.

Dated: April 11, 2003

Respectfully submitted,

Stanley M. Brand
D.C. Bar # 213082
Shaun M. Gehan
Maine Bar # 009380
Motion for Pro Hac Vice pending
923 Fifteenth Street, N.W.
Washington, D.C. 20005
(202) 662-9700

Counsel for Defendants Esther Hankerson, et al.


On this 11th day of April, 2003, a true and correct copy of Defendants' Reply to Plaintiff's Opposition for Motion to Dismiss were delivered via first-class mail to the following:

Patricia Mary Byrne, Esquire
Christopher J. Healing, Esquire
Wilmer Cutler & Pickering
2445 M Street, N. W.
Washington, D.C. 20037-1420

James Michael Cole, Esquire
William C. Edgar, Esquire
Rebecca A. Ford, Esquire
Bryan Cave LLP
700 13th Street, N.W.
Washington, D.C. 20005

Stephen R. Spivack, Esquire
Spriggs & Hollingsworth
1350 I Street, N.W.
9th Floor
Washington, D.C. 20005

E. Carrie Nixon
Reed Smith, LLP
1301 K Street, N.W.
Suite 1100-East Tower
Washington, D.C. 20005

Amy Jackson, Esquire
Trout & Richards, PLLC
1100 Connecticut Avenue, N.W.
Washington, D.C. 20036

Louis J. Martucci, Esquire
14452 Old Mill Road
Upper Marlboro, MD 20772

Fred Cooke, Esquire
Rubin, Winston, Diercks, Harris & Cooke
1155 Connecticut Avenue, N.W.
6th Floor
Washington, D.C. 20036

Lisa Alexis Jones, Esquire
Jones & Towns, PLLC
803 Florida Avenue, N.W.
Washington, D.C. 20001

Roland Ashby-Rier
5 V Street, N.W.
Washington, DC 20001-1012

Alfred E. Hubbard
7706 13th Street, N.W.
Washington, D.C.

Mary Baird Currie
1120 Michigan Avenue, NE
Washington, DC 20017-2610

Lucy R. Edwards, Esquire
3001 Georgia Avenue, N.W.
Washington, D.C. 20001

Barbara Bullock
1221 Massachusetts Avenue, N.W.
Washington, D.C. 20001

Vandy Jamison
1717 K Street, N.W., Suite 600
Washington, DC 20036

Mark Hanna, Esquire
George R. Murphy, Esquire
David, Cowell & Bowe
1155 15th Street, N.W.,
Suite 405
Washington, D.C. 20005

Robert Lourie, Esquire
O'Malley Miles Nylen & Gilmore PA
11785 Beltsville Drive
10th Floor
Calverton, MD 20705

Stanley M. Brand


1. These defendants are: Esther Hankerson, Janice S. Spencer, Jerolyn Spicer, Adolphus Brookins, Jr., H. Beryl Hager, Dorothy E. Duppins, Brenda Jenkins, Delores Haynes, Dorothy King, Theresa D. McDougald, Delores E. Timmons, Janice E. Waters, Deloris B. Brown, Sarah Crawley, Alan M. Friedman, Benita Nicholson, Elnora C. Oxendine, Margaret Jamison, and Theodore R. Vowels, Jr.

2. The Individual Defendants are former President Barbara Bullock, Special Assistant Gwendolyn Hemphill, and Treasurer James Baxter. Id. 1.

3. Paragraph 3 of the Amended Complaint, for example, lumps these Defendants (i.e., the Executive Board, including Esther Hankerson, Board member and General Vice President), with the WTU's Board of Trustees, and alleges general and conclusory breaches of financial oversight responsibilities. Am. Compl. 3. Not only do such vague allegations fail to meet the necessary "good cause" element of § 501(b), see infra at Part IV, it is clear that these groups have vastly different responsibilities with respect to financial matters. Compare Exec. Bd. Mem. at 3 (detailing the constitutional duties of the Executive Board and General Vice President), with Plaintiff's Complaint ("Pl.'s Compl."), Exh. 2, at 16-17 ("Constitution and Bylaws Washington Teachers' Union American Federation of Teachers Local 6") (specifying the duties of the Board of Trustees).

4. Further, the "demand," which is said to include a letter, a picket, and a membership motion, does not meet the legal prerequisite under § 501(b). See Exec. Bd. Mem. at III.B.

5. See O'Connor v. Freyman, 1985 WL 121, #1 (D.D.C 1985) (Exec. Bd. Mem., Exh. 1) (citing Horner v. Ferron, 362 F.2d 224, 228 (oth Cir.1966) cert. denied 385 U.S. 958 (1966)).

6. See also Yager v. Carey, 910 F. Supp. 704, 726-27 (D.D.C. 1995); O'Connor v. Freyman, 1985 WL 121 (D.D.C 1985); and International Brotherhood of Teamsters v. Hoffa, 242 F. Supp. 246, 250-51 (D.D.C. 1965).

7. Only in an oblique way are the demand made and the relief sought connected, in that Bullock is alleged to have requested the improper withholding (as an action "not authorized by the WTU Executive Board") as part of an overall alleged criminal operation. Am. Compl. ¶1. However, the connection between a demand that the "WTU Officers" explain why this mistake was made (months after the Individual Defendants were relieved of their duties for improprieties, it should be noted) and a suit to force reimbursement from all Defendants for the actions of a few is as tenuous as the demand to inspect books and the subsequent challenge to a dues increase in Flaherty.

8. These Defendants maintain, however, that the law as espoused in Commer v. McEntee, 145 Supp.2d 333, 338 (S.D.N.Y. 2001), is closer both to the statement of the law in Adams-Lundy, at 844 F.2d at 248 ("[W]e decide that § 501(b) requires a plaintiff to request the union to institute legal proceedings."), and the law as it stands in this Circuit. See supra n.6 and accompanying text.

9. That said, these Defendants deny that any of the allegations against them state a claim under § 501(b), nor have they violated any duty imposed on them by § 501(a).

10. As an example of this chaotic, often mixed message from which Plaintiff urges this Court
to find a demand, Plaintiff described "the purpose of the picket and demonstration [outside WTU and AFT headquarters in November] was `[u]nion members demonstrating against unfair dues, working conditions and misuse of our vital resources. We are demanding a election [sic] of New Executive Committee NOW.'" Am. Compl. ¶11 (quoting permit application, Compl., Exh. 6.2-.3) (italics added, second alteration in original). Yet, this is part of the mosaic of statements and behaviors from which Plaintiff seeks to draw his compliance with the demand requirement. Id. 11 40-52; see also supra note 12.

11. It is certainly not unreasonable for the Executive Board to be prudent in avoiding discussion of matters material and subject to an ongoing criminal investigation.

12. At least, those demands that were distilled into the Amended Complaint. Am. Compl. ¶¶40-49. In fact, Plaintiff's "demands" during the period of time at issue were multitudinous and wide-ranging. See, e.g., Compl., Exhs. 6, 6.1, 7, 7.1, and 8.1.

13. In this set of cases, the District of Colombia Court of Appeals overturned the apparent holding below that "good cause" standard of § 501 (b) requires a "`high probability that [Plaintiff's] allegations are true."' 98 F.3d at 1422 (quoting the opinion below). But while rejecting the perceived "heightened pleading standard," id., the Appeals Court did not specify a standard by which a judge should decide whether good cause exists on the face of the complaint. However, in Horner, from which the appeals court drew this test, the purpose of the "good cause" was discussed. "The requirement of section 501(b) that a plaintiff in such an action show `good cause' before being entitled to file the complaint is intended as a safeguard to the affected union against harassing and vexatious litigation brought without merit or good faith." Horner, 362 F.2d at 228 (citing Highway Truck Drivers and Helpers L. 107 v. Cohen, 182 F. Supp. 608, 622, fn. 10 (E.D. Pa. 1960), aff'd, 284 F.2d 162 (3d Cir. 1960)).

14. Of course, under George, 98 F.3d at 1422, this would not be an appropriate factor.

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