The Labor Management Reporting and Disclosure Act

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7^th Circuit Court of Appeals

Case Name: Christine Boardman v. Service Employees International Union

Case No.: 22-2957

Officials: Easterbrook, Wood, and Kirsch, Circuit Judges.

Focus: The Labor Management Reporting and Disclosure Act

Christine Boardman, the former president of Local 73—an affiliate of the Service Employees International Union (International)—was subjected to an emergency trusteeship imposed by the International due to internal conflicts. Boardman, in response, sued under the Labor Management Reporting and Disclosure Act, contending that the trusteeship was a pretextual retaliation against her protected speech.

The court sided with the defendants, acknowledging their argument that the trusteeship was essential to restore order and democratic processes within Local 73, particularly in light of the intense conflicts between Boardman and Secretary-Treasurer Matthew Brandon. The court reasoned that such a purpose fell within the permissible grounds for trusteeships outlined in the Act, which includes the restoration of democratic procedures.

Boardman’s assertion that the trusteeship was retaliatory was rejected by the court. It maintained that even if there was animosity between Boardman and Mary Kay Henry, the President of the International, this did not undermine the legitimate purpose behind the trusteeship. Additionally, the court found no evidence supporting Boardman’s claim that she was treated differently from other union members engaging in protected speech. Consequently, the court upheld the lower court’s decision to grant summary judgment in favor of the defendants.

Affirmed.

Decided 12/26/23

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