West v. Conrail

481 U. S. 35

April 6, 1987

Thomas West sued his railway for breach of collective bargaining agreement, and his union for inadequate representation. The litigation was brought under the auspices of the Railway Labor Act (RLA). Although the complaint was filed within six months of the alleged breaches, service was not effected until after the six month period was over. The National Labor Relations Act (NLRA), a closely analogous law to the RLA, said that both filing and service must be effectuated within six months, or else a claim is lost. The railway and union argued that this statute of limitations should apply.

Writing for a unanimous Court, Stevens agreed that the NLRA’s six month period should apply, but said that its requirement of service within that six month period need not be followed. The Federal Rules of Civil Procedure said that mere filing was enough to bring a claim within a statute of limitations. Stevens said that no more should be borrowed from the NLRA than needed. The six month period was needed because neither the RLA or the Federal Rules provided anything, but because the Federal Rules made clear that service within a statute of limitations was not necessary, that portion of the NLRA did not need to be borrowed.

Even though this case was only five pages long, it took me forever to figure out what the heck was going on. Once I finally understood it, the decision seemed kind of stupid and arbitrary. Frankly, I think the NLRA’s provisions should just be borrowed wholesale without involving the Federal Rules.


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