Stuart v. Local 727, International Brotherhood of Teamsters

Dist. Ct. erred in dismissing plaintiff’s Title VII claim at pleading stage of case, where plaintiff alleged that defendant union failed to refer plaintiff to certain driving jobs on account of her gender. Record showed that plaintiff never received any referrals in 4.5 years, even though there had been no shortage of driving jobs in said time period, and although defendant raised statute of limitations defense, record contained factual dispute regarding whether any referrals to others occurred within applicable 300-day limitations period. Moreover, Dist. Ct. harbored erroneous belief that plaintiff’s “failure to refer” claim was not actionable under Title VII.