National Right to Work Foundation’s Courageous Tennessean Wins Big in Union Discrimination Lawsuit


The following article is from the National Right to Work Legal Defense Foundation’s bi-monthly Foundation Action Newsletter, May/June 2022 edition. To view other editions of Foundation Action or to sign up for a free subscription, click here.

LIUNA union official denigrated employee’s faith and sent priest ‘corrective church readings’

“It’s one of the greatest things I’ve ever done in my life,” Frame said of his win over LIUNA officials. To learn more about his case, watch our video with the Frame Foundation attorney at the bottom of this page.

CLARKSVILLE, TN – Workers who seek free legal aid from the National Foundation for the Right to Work often defend their rights despite the real threats that union bosses pose to their livelihoods and their ability to provide for their families. For Tennessee employee Dorothy Frame, who just won a major settlement against Workers’ International Union (LIUNA) officials with the help of the Foundation, all that and more was in jeopardy. She believed that LIUNA officials’ forced dues demands violated her religion.

Frame filed a lawsuit against LIUNA in November 2021, claiming that union officials unlawfully discriminated against her by forcing her, in violation of her Catholic beliefs, to fund union activities through the compulsory payment of union dues. Frame voiced her religious objections to the union’s political activities, but union officials repeatedly dismissed and ridiculed her request for religious accommodation.

Under the settlement, as a condition of dismissing the lawsuit against LIUNA, union officials paid Frame $10,000 in damages. The settlement also required the lawyer for LIUNA officials to send a letter of apology to Frame for the improper conduct of the union.

Frame first requested religious accommodation in 2019, when she sent “a letter advising [LIUNA] of the conflict between her religious beliefs and her obligation to join or contribute to the Union.

Tennessee has a right to work law ensuring that workers in the state’s private sector cannot be required to pay dues as a condition of employment. But Fort Campbell, the location of the Blanchfield Army Community Hospital where Frame worked, may be an exclusive “federal enclave” not subject to state right-to-work law.

LIUNA officials: Workers’ religious objections to forced dues are ‘illegitimate’

Frame’s former employer, J&J Worldwide Service, maintains a closed-shop contract with LIUNA union bosses that requires employees to pay union dues or dues to keep their jobs.

Frame’s July 2019 letter included a message from his pastor supporting his request for religious accommodation. Federal law prohibits unions from discriminating against employees on the basis of religion and requires unions to provide accommodations to workers who object to paying dues on religious grounds.

Instead, LIUNA officials denigrated her beliefs. In addition to demanding that she provide “legitimate justification” for why her conflict with union activity warranted religious accommodation, a union lawyer claimed in a letter to Frame that her understanding of her faith was less than his own understanding of his faith. He even closed the letter by sending Ms. Frame and her priest some remedial church readings.

Frame then filed a discrimination complaint against LIUNA with the Equal Employment Opportunity Commission (EEOC) in December 2019. Even after the EEOC proceedings continued and Frame’s attorneys sent letters showing the conflict between the union’s position and his religious views, union officials always refused to accommodate him. beliefs and refused to return the money they took from her paycheck after she applied for housing.

Ultimately, the EEOC issued Frame a “right to sue” letter leading to his federal anti-discrimination lawsuit, filed by Foundation staff attorneys, resulting in his victory.

“Despite being the target of years of intimidation and discrimination by LIUNA officials, Ms. Frame refused to give up her religious beliefs and stood firm for her rights,” commented the president of the National Foundation for the Right to Work, Mark Mix. “She has now decisively prevailed against LIUNA’s unlawful attempt to force her to choose between remaining true to her beliefs and remaining employed.”

Forced Dues Privileges Open Door to Union Discrimination Against Workers

“The National Foundation for the Right to Work is proud to stand with principled workers like Ms. Frame. The privilege granted by the government to Big Labor to force rank-and-file workers to support the activities of union bosses creates fertile ground for anti-worker malfeasance and abuse,” Mix continued. “No American worker should have to pay tribute to a union they oppose simply to keep their job, whether their objections are religious or otherwise.”


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