DISCLAIMER: Any unofficial case summaries below are prepared by the clerk's office
as a courtesy to the reader. They are not part of the opinion of the court.
211640P.pdf 07/25/2022 Eric Brown v. AFSCME
U.S. Court of Appeals Case No: 21-1640
and No: 21-1684
U.S. District Court for the District of Minnesota
[PUBLISHED] [Colloton, Author, with Loken and Shepherd, Circuit Judges]
Civil case - Civil rights. In these cases, current and former Minnesota
state employees sought damages under Section 1983 for money deducted from
their paychecks by unions that represented their local bargaining unit.
The district court held that the unions were entitled to a defense against
liability under Section 1983 because they acted in good-faith reliance on
state statutes and existing judicial precedent. For a similar case, see
today's decision in Hoekman v. Education Minnesota, No. 21-1366. A
plaintiff who sues a private-party defendant based on the defendant's
employment of a state law that has been declared unconstitutional must
show that the defendant was not acting in good-faith reliance on that law;
here, the plaintiffs do not allege that that the unions subjectively
believed they were violating the rights of employees by collecting the
fees, so the court need not address whether such a showing would overcome
the unions' objectively reasonable reliance on the statute in question;
because the unions collected the fair share fees under Minn. Stat. Sec.
179A.06 at a time when the procedure used had been deemed constitutional
by the Supreme Court, their reliance on the statute was objectively
reasonable, and they were entitled to a good-faith defense.