Railway Mail Assn. v. Corsi
Decided on June 18, 1945; 326 US 88


I. ISSUES II. CASE SUMMARY III. AMICI CURIAE IV. DECISION V. WIN OR LOSS?
I. ISSUES:

A. Issues Discussed: Racial discrimination, equal protection

B. Legal Question Presented:

Is Appellant a "labor organization" subject to the provisions of the New York Civil Rights Law, which provide that no labor organization shall deny "by reason of race, color or creed" membership and/or equal treatment to its members, and if it is, do the provisions "violate the due process and equal protection clauses of the Fourteenth Amendment of the federal Constitution and [are they] in conflict with the federal power over post offices and post roads. Article I, Section 8, Clause 7, of the federal Constitution?"

II. CASE SUMMARY:

A. Background:

"Section 43, and related Sections 41 and 45, of the New York Civil Rights Law which provide, under penalty against its officers and members, that no labor organization shall deny a person membership by reason of race, color or creed, or deny to any of its members, by reason of race, color or creed, equal treatment in the designation of its members for employment, promotion or dismissal by an employer."

The Appellant's "constitution limits membership in the association to eligible postal clerks who are of the Caucasian race, or native American Indians." Appellants contend "that it was not a 'labor organization' subject to these sections...

The appellant filed suit against the Industrial Commissioner in a state court for a declaratory judgment to determine the validity of Section 43, and related provisions, and for an injunction restraining its enforcement against the Appellant. A state Supreme Court entered judgment for the appellant finding that it was not a 'labor organization' as defined in Section 43 of the state statute.

On appeal to the Appellate Division, this judgment was reversed, the appellate court finding that appellant was covered by Section 43 and that Section 43 as applied to appellant did not violate the federal Constitution. On appeal to the New York Court of Appeals, the judgment against the appellant was affirmed."

On appeal the US Supreme Court affirmed.

B. Counsel of Record:
ACLU Side
(Respondent/Appellee)
Opposing Side
(Petitioner/Appellant)
Unavailable Unavailable
C. The Arguments:
ACLU Side
(Respondent/Appellee)
Opposing Side
(Petitioner/Appellant)
Unavailable Unavailable
III. AMICI CURIAE:
ACLU Side
(Respondent/Appellee)
Opposing Side
(Petitioner/Appellant)
Mr. Wendell P. Brown, of Albany, N.Y., for appellee. Mr. Daniel J. Dugan, of Albany, N.Y., for appellant.
IV. THE SUPREME COURT'S DECISION:

"1) Appellant contends that... the New York Civil Rights Law, as applied to appellant offends the due process clause of the Fourteenth Amendment as an interference with its right of selection to membership and abridgment of its property rights and liberty of contract. We have here a prohibition of discrimination in membership or union services on account of race, creed or color. A judicial determination that such legislation violated the Fourteenth Amendment would be a distortion of the policy manifested in that amendment which was adopted to prevent state legislation designed to perpetuate discrimination on the basis of race or color..."  

2) Appellant argues that Section 43 of the New York Civil Rights Law denies it equal protection because "Article 20 of the New York Labor Law, conferring certain rights on employees and labor organizations with respect to organization and collective bargaining, excludes from the operations of its provisions labor organizations, such as the appellant, whose members are 'employees of the state,' [and] that the state's failure to extend Article 20 to include the appellant denies it equal protection. A state does not deny equal protection because it regulates the membership of appellant but fails to extend to organizations of government employees provisions relating to collective bargaining. Under customary practices government employees do not bargain collectively with their employer...

3) Appellant [contends] that Section 43, and related provisions, are repugnant to Article I, Section 8, Clause 7, of the federal Constitution which confers on Congress the authority over postal matters... Section 43 does not impinge on the federal mail service or the power of the government to conduct it...Section 43 is confined in its application to a purely private organization deriving no financial or other statutory support or recognition from the federal government and which in no way acts as an instrumentality of the federal government in performance of its postal functions."

The US Supreme Court affirmed the judgment of the Supreme Court of the State of New York.

Justice Vote: 9 Pro vs. 0 Con

  • Reed, S. Pro (Wrote majority opinion)
  • Frankfurter, F. Pro (Wrote concurring opinion)
  • Rutledge, W. Pro (Wrote concurring opinion)
  • Douglas, W. Pro (Joined majority opinion)
  • Roberts, O. Pro (Joined majority opinion)
  • Black, H. Pro (Joined majority opinion)
  • Stone, H. Pro (Joined majority opinion)
  • Murphy, F. Pro (Joined majority opinion)
  • Jackson, R. Pro (Joined majority opinion)
V. A WIN OR LOSS FOR THE ACLU?

The ACLU, as amicus curiae, urged affirmance of the judgment of the Supreme Court of new York; the Supreme Court affirmed in a 9-0 vote, giving the ACLU an apparent win.