Translate
Text Highlighter

Bookmark

PDF

Share

Report a problem
AMICUS AI
Citation Codes
Equivalent Citations
citation codes
Docket Number
Attorney(S)
Judges
Are you a practicing lawyer?
Enhance your digital presence and reach by creating a Casemine profile.
Upload pleading to use the new AI search
Cites
Cited by
Citation Codes
Equivalent Citations
citation codes
Docket Number
Attorney(S)
Judges
Smart Summary

Packer v. Dana Corporation — Michigan Court of Appeals (Dec. 5, 1986)

Factual and Procedural Background

Plaintiff was employed by defendants from July 1973 until January 1981. During this period plaintiff developed an alcohol problem. The parties agreed that plaintiff would attend an alcohol treatment program as a condition to retaining his job. Plaintiff failed to attend a scheduled meeting and was fired in January 1981. This suit was filed in August 1983. At all pertinent times plaintiff was covered by a collective bargaining agreement. Defendants moved for summary judgment and accelerated judgment. The trial court granted defendants' motion for summary judgment, holding that § 301 of the Labor Management Relations Act (29 U.S.C. § 185(a)) was plaintiff's exclusive remedy and that the circuit court therefore lacked jurisdiction. Plaintiff appealed as of right.

Legal Issues Presented

  1. Whether the trial court was correct in holding that federal courts had exclusive jurisdiction under § 301 of the Labor Management Relations Act (29 U.S.C. § 185(a)).
  2. Whether plaintiff's claim is time-barred under the applicable statute of limitations (as interpreted under 29 U.S.C. § 160(b) and Del Costello v International Brotherhood of Teamsters).

Arguments of the Parties

The opinion does not contain a detailed account of the parties' legal arguments.

Table of Precedents Cited

Precedent Rule or Principle Cited For Application by the Court
Harris v Edward Hyman Co, 664 F.2d 943 (CA 5, 1981), reh den 669 F.2d 733 Used to show that federal courts do not have exclusive jurisdiction in the circumstances at issue (i.e., the trial court's statement that federal courts had exclusive jurisdiction was incorrect). The court cited this authority to reject the trial court's jurisdictional rationale (but did not reverse the judgment on that ground).
Ciba-Geigy Corp v Local 2548, United Textile Workers of America, AFL-CIO, 391 F. Supp. 287, 296 (D RI, 1975) Used similarly to indicate that federal courts did not have exclusive jurisdiction in the circumstances at issue. The court relied on this authority to conclude the trial court was incorrect about exclusive federal jurisdiction (while ultimately affirming the judgment on other grounds).
Robertson v Detroit, 131 Mich. App. 594; 345 N.W.2d 605 (1983) Supports the principle that when a trial court reaches the right result for the wrong reason, an appellate court need not reverse. The court invoked this principle to justify affirming the grant of summary judgment despite the trial court's incorrect jurisdictional reasoning.
Del Costello v International Brotherhood of Teamsters, 462 U.S. 151; 76 L Ed 2d 476; 103 S Ct 2281 (1983) Applied with 29 U.S.C. § 160(b) to establish that the applicable period of limitation is six months for the type of claim at issue. The court held that because plaintiff waited approximately 2½ years to file suit, the claim was barred by the six-month limitation and summary judgment was therefore proper.

Court's Reasoning and Analysis

The Court of Appeals identified two key legal points from the opinion's analysis. First, it concluded that the trial court was incorrect in stating that federal courts had exclusive jurisdiction under § 301 of the Labor Management Relations Act, citing Harris v Edward Hyman Co and Ciba-Geigy Corp v Local 2548 in support of that conclusion. Second, the court determined that the grant of summary judgment could be sustained on a different ground: the claim was time-barred. Citing 29 U.S.C. § 160(b) together with Del Costello v International Brotherhood of Teamsters, the court treated the applicable statute of limitations as six months. Because plaintiff filed suit roughly 2½ years after termination, the court found the claim barred by the six-month limitation. The court also relied on the principle from Robertson v Detroit that an appellate court need not reverse when the trial court reached the right result for the wrong reason; applying that principle, the court affirmed the summary judgment despite the trial court's incorrect jurisdictional basis.

Holding and Implications

AFFIRMED

Holding: The Court of Appeals affirmed the trial court's grant of summary judgment.

Implications: The direct consequence is that plaintiff's claim is barred by the six-month limitation period under 29 U.S.C. § 160(b) as interpreted by Del Costello, because plaintiff filed suit approximately 2½ years after termination. The court rejected the trial court's exclusive-jurisdiction rationale but affirmed the result on statute-of-limitations grounds. The opinion does not announce any broader new precedent beyond applying existing authorities to these facts.

PACKER v DANA CORPORATION

PER CURIAM.

Plaintiff was employed by defendants from July of 1973 until January, 1981. During this period of time plaintiff developed an alcohol problem. The parties agreed that plaintiff would attend an alcohol treatment program as a condition to retaining his job. Plaintiff failed to attend a scheduled meeting and was fired in January of 1981. This suit was filed in August of 1983. At all pertinent times, plaintiff was covered by a collective bargaining agreement. Defendants brought motions for summary judgment and accelerated judgment. The trial court granted defendants' motion for summary judgment holding that § 301 of the Labor Management Relations Act, 29 U.S.C. § 185(a), was plaintiff's exclusive remedy and that, therefore, the circuit court lacked jurisdiction. Plaintiff now appeals as of right.

The trial court was incorrect in stating that federal courts had exclusive jurisdiction. Harris v Edward Hyman Co, 664 F.2d 943 (CA 5, 1981), reh den 669 F.2d 733, and Ciba-Geigy Corp v Local 2548, United Textile Workers of America, AFL-CIO, 391 F. Supp. 287, 296 (D RI, 1975). The grant of summary judgment, however, need not be reversed. When a trial court reaches the right result for the wrong reason we do not reverse. Robertson v Detroit, 131 Mich. App. 594; 345 N.W.2d 605 (1983).

The reason that summary judgment was correct is because the applicable period of limitation is six months. See 29 U.S.C. § 160(b) and Del Costello v International Brotherhood of Teamsters, 462 U.S. 151; 76 L Ed 2d 476; 103 S Ct 2281 (1983). As plaintiff waited 2 1/2 years, his claim is barred. Accordingly, the grant of summary judgment is affirmed.

Affirmed.

Use AI to get other relevant cases.

Comments

PACKER v. DANA CORPORATION
(Feb 5, 1986)