DISCLAIMER: The following unofficial case summaries are prepared by the clerk's office
as a courtesy to the reader. They are not part of the opinion of the court.
211366P.pdf 07/25/2022 Linda Hoekman v. Education Minnesota
U.S. Court of Appeals Case No: 21-1366
and No: 21-1372
and No: 21-2675
and No: 21-2687
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 Minnesota state employees sued
unions seeking monetary relief based on the amount of so-called "fair
share" fees that had been deducted from their paychecks for the benefit of
the unions. See Janus v. American Federation of State, County, & Municipal
Employees, 138 S.Ct. 2448 (2018). The district court granted summary
judgment for the unions, and plaintiffs appeal. Held: public-sector unions
are entitled to a good-faith defense to liability under Section 1983 if
they relied on a then-valid statute to collect fair shares from a
non-union member employee before Janus was decided. See also Brown v.
American Federation of State, County, and Municipal Employees, No. 21-1640
which the court issues this date. Plaintiffs Buros and Piekarski's claims
fail because the unions were private actors and were not acting under
color of state law; the district court did not err in awarding certain
litigation costs to the unions; the unions were not required to move to
dismiss the case, thereby reducing potential costs, rather than wait and
file motions for summary judgment.