Conley v. Gibson Case Brief Summary | Law Case Explained

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Conley v. Gibson | 355 U.S. 42 (1957)

How specific does a complaint need to be? Does it need lots of solid facts, or will just an outline do? The United States Supreme Court pondered this question in the labor-union case Conley versus Gibson.

A number of African Americans worked for the Texas and New Orleans Railroad at its Houston Freight House. They were all members of a labor union called the Brotherhood of Railway and Steamship Clerks. The union represented them in matters relating to the Railway Labor Act. A contract between the union and the railroad protected employees in matters of seniority and discharge.

In 1954, the railroad announced it was abolishing forty-five positions, all of them then held by African Americans. In fact, the railroad hadn’t abolished the positions at all. It had instead fired or demoted the African American workers in order to replace them with white employees. The African American employees asked the union to plead their case, but it did nothing.

The employees sued in federal district court in Texas, claiming that the union had failed to represent African American employees equally and in good faith. The district court dismissed the claim, holding that the employees had failed to state specific facts to support their general allegations of discrimination. The Court of Appeals for the Fifth Circuit affirmed the dismissal. The United States Supreme Court granted cert.

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