Conley v. Gibson

Local 28 of the Brotherhood of Railway and Steamship Clerks allegedly conspired with a railroad to lay off 45 African American employees under the guise of a workforce reduction, rehiring only some with lost seniority, and consistently failed to represent Black members as well as white members despite repeated requests for help. Conley and other Black union members (plaintiffs) sued the Brotherhood, Local 28, and officer Gibson (defendant) for violating their right to fair representation under the Railway Labor Act; the district court dismissed for failure to state a claim, and the Fifth Circuit affirmed.