litigation across the country would subvert the reform bogging the Court officers down in duplicative, harassing, and perhaps frivolous litigation," id.; and (3) "judicial economy demands that similar issues not be litigated multiple times in different districts. . . ." Id. at 1048.
On appeal, the Second Circuit affirmed this Court's ruling. Quoting the Supreme Court, the Second Circuit explained that "the All Writs Act empowers courts to issue extraordinary writs 'as may be necessary or appropriate to effectuate and prevent the frustration of orders it has previously issued.'" United States v. International Bhd. of Teamsters [All Writs Act Affirmance], 907 F.2d 277, 280 (2d Cir. 1990) (quoting United States v. New York Tel., 434 U.S. 159, 172, 54 L. Ed. 2d 376, 98 S. Ct. 364 (1977)). The Second Circuit held that this Court "acted well within its authority under the All Writs Act" in enjoining all members and affiliates of the IBT from litigating issues related to the Consent Decree in any court other than the Southern District of New York, and specifically accepted this Court's reasons for doing so. 907 F.2d at 280-81. Finally, the Second Circuit rejected appellants' claim that this Court lacked personal jurisdiction over them both because "injunctions may be issued against non-parties under the All Writs Act," and because "the All Writs Act requires no more than that persons enjoined have the 'minimum contacts' that are constitutionally required under due process." Id. at 281 (quotations and citations omitted). Subsequent to the Second Circuit's All Writs Act Affirmance, this Court has issued other orders enjoining parties from pursuing suits that implicated the Consent Decree in other courts. United States v. International Bhd. of Teamsters [Erbacci], 911 F. Supp. 743 (S.D.N.Y. 1996); Darrow, 896 F. Supp. 1339.
In the Local 714 Case, plaintiff IBT imposed an emergency trusteeship on Local 714 pursuant to a recommendation of the IRB, pursuant to the rules that govern the IRB. United States v. International Bhd. of Teamsters [IRB Rules Decision], 829 F. Supp. 602 (S.D.N.Y. 1993). According to the IRB Rules, following this referral the IBT "shall promptly undertake whatever action is appropriate under the circumstances to resolve the referred matter, as provided by the IBT Constitution, applicable law, and these Rules," and "shall resolve the referred matter within the time prescribed by the IRB. . . ." Id. at 605, (Rule I.5.) The IRB Rules further mandate that "the IRB shall monitor all matters that it has referred for action," and "may also direct the Chief Investigator to ensure that the IBT entity resolves a referred matter in a lawful and responsible manner." Id.
The IRB and the IRB Rules were established with this Court's approval pursuant to specific provisions of the Consent Decree. Consent Decree, P G. Consequently, any actions taken by the IRB, or by the IBT upon recommendation of the IRB, not only implicate the Consent Decree, but also are crucial to the Consent Decree's effectiveness. Accordingly, this Court finds that the actions taken by the IBT in the instant case implicate the Consent Decree.
Similarly, Local 714's challenges to the IBT's actions in the Local 714 case implicate the Consent Decree. Local 714's contention that the IBT's imposition of trusteeship over Local 714 violates both the IBT Constitution and the LMRDA challenges the IRB's authority to "monitor all matters that it has referred for action," and to "direct the Chief Investigator to ensure that the IBT entity resolves the referred matter in a lawful, responsible, and timely manner." IRB Rules, 829 F. Supp. at 605 (Rule I.5). Any action that challenges or weakens the ability of the IRB to perform the duties imposed upon it by the Consent Decree clearly implicates the Consent Decree and endangers the purposes for which it was created--namely, eradicating the influences of corruption and organized crime from the IBT. Accordingly, this Court finds that Local 714's challenge to the IBT's decision to impose a trusteeship over Local 714 implicates the Consent Decree.
As previously explained, this Court found that its original All Writs Act Decision was necessary for three reasons. Each of these reasons compels this Court to enjoin the parties in the Local 714 Case. First, "there exists a significant risk of subjecting the Consent Decree to inconsistent interpretations and the Court Officers to inconsistent judgments," which "would encourage forum shopping by subordinate entities seeking a sympathetic ruling," All Writs Act Decision, 728 F. Supp. at 1047. Although this Court is confident that Judge Andersen is capable of properly adjudicating the instant case, the need for consistency among Consent Decree case law demands that all Consent Decree litigation be brought in one Court--the Southern District of New York.
Second, "widespread litigation across the country would subvert the reform bogging the Court officers down in a duplicative, harassing, and perhaps frivolous litigation." Id. If the Local 714 Case remains in the Northern District of Illinois, the IBT and IRB will face prolonged litigation in a distant judicial district. Moreover, this Court is aware of recent challenges in federal district courts in Texas and Pennsylvania to trusteeships that have been imposed by the IBT on IBT locals. The time and effort required to pursue countrywide litigation regarding the Consent Decree would hinder both the IBT and IRB's ability to perform their respective disciplinary and remedial duties under the Consent Decree.
Third, this Court's All Writs Act Decision was designed to promote judicial economy, and judicial economy is best served by enjoining the parties in the Local 714 Case. "Because this Court has overseen the Consent Decree from its inception, this Court has thorough knowledge of the myriad decisions that make up the law of this case." Darrow, 896 F. Supp. at 1345. In fact, just yesterday, this Court heard argument regarding an almost identical dispute over the imposition of an emergency trusteeship by the IBT on an IBT Local in Texas. See August 22, 1996, Hearing, International Bhd. of Teamsters v. Local Union 745 of the IBT, 96 Civ. 6328 (DNE). Consequently, interests of judicial economy militate in favor of adjudicating the Local 714 Case in this Court.
Because this Court finds that the Local 714 Case implicates the Consent Decree, this Court holds that: (1) the All Writs Act confers jurisdiction over this Court to adjudicate this case; (2) this Court's All Writs Act Decision requires that the Local 714 Case be adjudicated in this Court; and (3) this case should be transferred immediately to this Court.
IT IS HEREBY ORDERED THAT plaintiffs in International Bhd. of Teamsters v. Local Union 714 of the IBT, 96 Civ. 4903 (N.D. Ill.) (WRA) are enjoined from pursuing that action in any court or forum in any jurisdiction except this Court.
IT IS FURTHER ORDERED THAT the case International Bhd. of Teamsters v. Local Union 714 of the IBT, 96 Civ. 4903 (N.D. Ill.) (WRA) be transferred to this Court immediately.
Dated: New York, New York
August 26, 1996
David N. Edelstein