Ackley v. Western Conference of Teamsters

In Ackley v. Western Conference of Teamsters, 958 F.2d 1463 (9th Cir.1992), a union member sued his union under the Labor-Management Reporting and Disclosure Act of 1959 ("LMRDA") Sec. 101(a) because the union failed to disclose material changes in a proposed renewal collective bargaining agreement before submitting it to the membership for a ratification vote. The plaintiff argued that Sec. 101(a)(1), which guarantees union members the equal right to vote in an election, guaranteed members meaningful information about the contract. The court held that, although the LMRDA might require meaningful disclosure for elections required under the LMRDA, that right did not apply in the particular situation because the right to a ratification vote was provided by the union rules alone and was not required by the statute.