holding that participation of individuals was not required where the district court would not determine damages because "the unique facts of each UAW member's claim will have to be considered by the proper state authorities [post-judgment] before any member will be able to receive the benefits allegedly due him"
How later courts described this case
- holding that participation of individuals was not required where the district court would not determine damages because "the unique facts of each UAW member's claim will have to be considered by the proper state authorities [post-judgment] before any member will be able to receive the benefits allegedly due him"
- reasoning that “there is little question that the interests” of a union advocating for its members’ unemployment benefits were “germane to the organization’s purpose” when one of the goals enumerated in 50 the union’s constitution was to advocate “on a national scale” for benefits
- holding that union could litigate case without participation of any member where only question was whether Secretary properly interpreted statutory provision and once the legal issue were resolved the amount of damages per union member could be left to state authorities
- concluding that “[n]either the claims nor the relief require[d] the participation of [the association’s] members” where the association’s “petition turn[ed] entirely on whether [the Department of the] Interior complied with its statutory obligations”
Written by the judges who cited it.
The opinion
Justice White,
with whom The Chief Justice and Justice Rehnquist join, dissenting.
I disagree with the Court’s conclusion that the District Court properly exercised jurisdiction over this case.
Section 239(d) of the Trade Act of 1974, 19 U. S. C. § 2311 (d), provides that “[a] determination by a cooperating State agency with respect to entitlement to program benefits ... is subject to review in the same manner and to the same extent as determinations under the applicable State law [regarding unemployment compensation benefits] and only in that manner and to that extent.” The legislative history explains that “[t]he bill would have the effect of channeling all questions arising from determinations by State agencies through the normal State review procedure.” S. Rep. No. 93-1298, p. 139 (1974). Congress thus expressed the intent that once a claim for trade readjustment allowance (TRA) benefits is submitted to a cooperating state agency, the agency and state courts shall have exclusive jurisdiction *294 to determine all questions, legal as well as factual, regarding the claim.
The Court treats § 239(d) as inapplicable to the present case on the ground that petitioners have not requested federal-court review of any particular benefit determination under the relevant federal guideline, but instead challenge the guideline itself. Ante, at 285. The distinction between a challenge to the guideline and a challenge to benefit determinations might be meaningful if petitioners had only challenged the application of the guideline to as-yet-unsubmitted claims, but that is not this case. At the time the District Court entered its judgment, the guideline at issue had been superseded for nearly 22 months, and the only live controversy related to the cooperating state agencies’ applications of the guideline to already-submitted claims. 1 Thus, this suit is precluded by Congress’ clearly expressed intent to commit to the state review process the adjudication .of all questions regarding TRA benefit claims under submission to a state agency.
In explaining its holding that § 239(d) does not apply to this case, the Court states that “although review of individual eligibility determinations in certain benefit programs may be confined by state and federal law to state administrative and judicial processes, claims that a program is being operated in contravention of a federal statute or the Constitution can nonetheless be brought in federal court.” Ibid. If the Court means that this case could have been brought even if the underlying benefit claims were state unemployment compensation claims, I disagree. In such a case, petitioners’ *295 suit, which seeks declaratory and injunctive relief for the sole purpose of providing a predicate for the recovery of already-accrued benefit claims in state court, would have been barred by the Eleventh Amendment. Green v. Mansour, 474 U. S. 64 (1985). 2 Of course, the Eleventh Amendment does not directly apply in the present case, since TRA benefits are paid entirely from federal funds, but what § 239(d) commands a federal court to do is treat questions arising from TRA benefit determinations as if they were questions arising from benefit determinations under state unemployment compensation law. Under that standard, this is not a case that should be adjudicated by the federal courts. 3 Accordingly, I dissent from the Court’s decision to address petitioners’ claims on the merits.
The claims in this case related to weeks of unemployment beginning prior to October 1, 1981. Brief for Petitioners 4, n. 4. When the District Court entered its judgment on July 28,1983, the relief granted related only to already-accrued claims for periods 22 months past or older. The record does not indicate that any unadjudicated claims for the period preceding October 1, 1981, remained outstanding at the time the District Court’s opinion issued.
The cases cited by the Court that involve claims for state unemployment compensation benefits — Ohio Bureau of Employment Services v. Hodory, 431 U. S. 471 (1977), Fusari v. Steinberg, 419 U. S. 379 (1975), and California Dept. of Human Resources Development v. Java, 402 U. S. 121 (1971)—are not to the contrary. These cases concern requests for declarations or injunctions that pertain at least in part to future claims for benefits, see, e. g., Hodory, supra, at 475 , which is not true of petitioners’ suit as of the time the District Court issued its judgment, see n. 1, supra. Also, whether or not the Eleventh Amendment might have been a bar to any aspect of the relief sought in Hodory, Fusari, or Java , the defendant state agency failed to raise the issue.
Christian v. New York Dept. of Labor, 414 U. S. 614 (1974), is not sound support for the Court’s conclusion that the present case is properly in federal court. In Christian , the Court never directly considered the jurisdictional implications of 5 U. S. C. § 8502 , the analogue of § 239(d) in this case. The only jurisdictional question the Court squarely addressed was whether mandamus jurisdiction lay against the Secretary of Labor, and the Secretary in fact conceded that such jurisdiction was proper. Id., at 617, n. 3. Arguably, any bar to federal-court adjudication presented by the jurisdictional statute in Christian is, like an Eleventh Amendment bar, waivable by the defendant. In any event, the Court’s failure to squarely consider the jurisdictional question in Christian makes it inappropriate to rely on that case for guidance in determining the jurisdictional question here.