The plaintiff union sued former employees and officials associated with a rival union following the creation of a new local that successfully organized workers previously represented by the plaintiff.
The plaintiffs alleged breaches of fiduciary duty, breach of employee duties of loyalty and confidentiality, and unlawful interference with contractual relations.
The court held the principal departing employee was not a fiduciary and that most information used in the organizing campaign was either public or not proven to have been misused.
However, several former employees breached basic duties of loyalty by preparing and initiating a competing organizing campaign before resigning and by failing to give reasonable notice of departure.
The court rejected claims of tortious interference against the rival union and its representatives.
Limited damages were awarded against the former employees for breach of employee duties.
