View source for Marquez v. Screen Actors Guild Inc.

{{Use mdy dates|date=September 2023}}
{{Infobox SCOTUS case
|Litigants=Marquez v. Screen Actors Guild Inc.
|ArgueDate=October 5
|ArgueYear=1998
|DecideDate=November 3
|DecideYear=1998
|FullName=Naomi Marquez, Petitioner v. Screen Actors Guild, Incorporated, et al.
|USVol=525
|USPage=33
|ParallelCitations=119 S. Ct. 292; 142 [[L. Ed. 2d]] 242; 1998 [[U.S. LEXIS]] 7110; 67 U.S.L.W. 4001; 136 Lab. Cas. ([[CCH (company)|CCH]]) ¶ 10,274; 159 L.R.R.M. 2641; 98 Cal. Daily Op. Service 8181; 98 Daily Journal DAR 11327
|Prior=On writ of cert. to the United States Court of Appeals for the Ninth Circuit
|Subsequent=None
|Holding=The union ([[Screen Actors Guild|SAG]]) did not breach its [[duty of fair representation]] merely by negotiating a union security clause that uses the language derived from the [[National Labor Relations Act|NLRA]] § 8(a)(3) without explaining in the contract agreement the Court's interpretation of that language.
|Majority=O'Connor
|JoinMajority=''unanimous''
|Concurrence=Kennedy
|JoinConcurrence=Thomas
|LawsApplied=[[National Labor Relations Act]]
}}
'''''Marquez v. Screen Actors Guild Inc.''''', 525 U.S. 33 (1998), was a [[Supreme Court of the United States|United States Supreme Court]] decision involving the validity of a [[union shop contract]].<ref>{{ussc|name=Marquez v. Screen Actors Guild Inc.|525|33|1998}}.</ref>
== Background ==
The petitioner Naomi Marquez is a part-time actress who successfully auditioned for a one-line role in ''[[Medicine Ball (TV series)|Medicine Ball]]'', a television series produced by Lakeside Productions. Pursuant to the union agreement Lakeside Productions had with the [[Screen Actors Guild]] (SAG), Lakeside contacted the SAG to verify that Marquez met the requirements of the union security clause.
It turns out that Marquez had previously worked in the motion picture industry for more than 30 days, thus the union security clause was triggered and Marquez was required to pay union fees before she could work at Lakeside.
The petitioner tried to negotiate with the [[Screen Actors Guild|SAG]] which would allow her to pay the union fees after she completed her work with Lakeside. The negotiations did not result in any compromise. On the day the part was supposed to be filmed, Marquez still had not paid her union dues and fees. Lakeside hired a different actress to fill in the part. At some point afterwards, the [[Screen Actors Guild|SAG]] faxed a letter to Lakeside that it had no objections to the petitioner working in the production, but it was too late for filming had already started on schedule with the replacement actress.
The petitioner filed a suit against the [[Screen Actors Guild|SAG]] and Lakeside claiming that they had breached its duty of fair representation by negotiating and enforcing a union security clause that used language from [[National Labor Relations Act|NLRA]] § 8(a)(3) but did not include the Court's rulings and explanation of rights in the terms of the agreement to intentionally mislead the workers within the union.
At issue was whether a union breaches its duty of fair representation by negotiating a union security clause that uses statutory language without articulating the Court's interpretation of that language.
== Opinion of the Court ==
The Court unanimously denied Marquez's claim.<ref>{{cite court |litigants=Marquez v. Screen Actors Guild, Inc. |court=9th Cir. |date=1998 |url=https://www.oyez.org/cases/1998/97-1056}}</ref>
The Court said that the statutory language incorporates all the refinements associated with the language, is a shorthand description of the worker's legal rights. The Court explained that if the petitioner's logic was used, there would be no stopping point because all contracts would have to spell out every intricacy of every term in the contract. Contracts would thus become massive, and yet there would be no real benefit from the increase in mass. The Court decided that it was perfectly reasonable for the union to use terms of art in a contract.
''[[NLRB v. General Motors Corp.]]'': An employee can satisfy [[National Labor Relations Act|NLRA]] § 8(a)(3) "membership" condition merely by paying to the union an amount equal to its initiation fees and dues.
''[[Communications Workers of America v. Beck]]'': [[National Labor Relations Act|NLRA]] § 8(a)(3) does not permit unions to exact fees or dues over the objection of nonmembers for activities that are not germane to collective bargaining, grievance adjustment, or contract administration.
== References ==
{{reflist}}
[[Category:United States labor case law]]
[[Category:United States Supreme Court cases]]
[[Category:United States Supreme Court cases of the Rehnquist Court]]
[[Category:Screen Actors Guild]]
[[Category:Labor relations in the United States]]
[[Category:1998 in United States case law]]