Chamber of Commerce of United States v. Brown, 554 U.S. 60 (2008)
Primary Holding
The California statute Assembly Bill 1889, which prohibits certain employers receiving state funds from using those funds to assist, promote, or deter union organizing, is preempted by federal law that mandates certain zones of labor activity be unregulated.
In the case of Chamber of Commerce of the United States v. Brown, the Supreme Court decided that a California law (AB 1889) that prevented certain employers from using state funds to influence union organizing was overruled by federal law. This matters because it means that employers can use state money to promote or oppose union activities, which could affect workers' rights to organize. This case is relevant if you're a worker trying to understand your rights regarding union membership and whether your employer can influence your decision using state funds.
AI-generated plain-language summary to help you understand this case
In the case of Chamber of Commerce of United States v. Brown, the underlying dispute arose from California's enactment of Assembly Bill 1889 (AB 1889), which prohibits certain employers receiving state funds from using those funds to assist, promote, or deter union organizing. The statute specifically targets employers that receive state grants, contracts, or other financial support, mandating that they cannot use state resources to influence employees' decisions regarding union membership or support. The law was designed to uphold the policy that the state should not interfere with employees' choices about union representation, and it includes a comprehensive enforcement mechanism requiring employers to certify compliance and maintain records to demonstrate that state funds were not misused. The procedural history of the case began when the Chamber of Commerce of the United States and other petitioners challenged the constitutionality of AB 1889, arguing that its provisions were preempted by federal law governing labor relations. The case was brought before the United States Court of Appeals for the Ninth Circuit, which upheld the statute. Subsequently, the petitioners sought a writ of certiorari to the Supreme Court, which agreed to hear the case, leading to the opinion delivered on June 19, 2008. The relevant background context includes the legislative intent behind AB 1889, which aimed to prevent the use of state funds to influence labor organizing efforts, thereby reinforcing the state's non-interference policy in employee unionization decisions. The law explicitly outlines the types of activities that are prohibited and establishes penalties for violations, including the potential for civil penalties that double the amount of misused funds. This legal framework reflects broader tensions between state labor policies and federal labor laws, particularly regarding the regulation of employer conduct in union-related activities.
Whether the provisions of California's Assembly Bill 1889, which prohibit certain employers receiving state funds from using those funds to assist, promote, or deter union organizing, are preempted by federal law that mandates certain zones of labor activity be unregulated.
The judgment is vacated and remanded for further proceedings.
- Court
- Supreme Court
- Decision Date
- March 19, 2008
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Stevens
- Damages Awarded
- N/A
- Data Quality
- high
Davenport v. Washington Ed. Assn., 551 U.S. 177 (2007)
Consumer WonThe First Amendment does not require public-sector unions to obtain affirmative consent from nonmembers before using their agency fees for purposes not chargeable under Abood, thus upholding the constitutionality of Washington's law that prohibits such use without consent.
Preston v. Ferrer, 552 U.S. 346 (2008)
Consumer LostThe Federal Arbitration Act (FAA) supersedes state laws that require certain disputes to be resolved in a judicial or administrative forum, allowing parties who agree to arbitrate all questions arising under a contract to have those disputes resolved by an arbitrator instead.
Whitman v. Department of Transportation, 547 U.S. 512 (2006)
Mixed OutcomeThe Court held that the jurisdiction of federal courts to review employment-related claims of federal employees is not conferred by 5 U.S.C. §7121(a)(1), but such jurisdiction is not divested by the Civil Service Reform Act (CSRA), allowing for potential claims to be pursued under 28 U.S.C. §1331 if they arise under the Constitution or federal law.
San Remo Hotel, L. P. v. City and County of San Francisco, 545 U.S. 323 (2005)
Consumer LostFederal courts cannot create an exception to the full faith and credit statute, 28 U.S.C. §1738, for claims brought under the Takings Clause of the Fifth Amendment, thereby affirming that state court decisions on takings claims must be respected in federal court.