Constitutional Law – State Action – Effect of State Court Interpretation of a Contract

Mrs. Doris Walker, president of her local union, was discharged by Cutter Laboratories in 1949 because of membership in the Communist Party and falsification of her employment application. The employer acquired knowledge of these facts in 1947, but did not act at that time to avoid charges of persecuting a union officer. The union, pursuant to the collective bargaining agreement, which authorized discharge for “just cause” only, sought and obtained reinstatement from the arbitration board, which action was affirmed by the district court of appeal, but reversed by the California Supreme Court. On certiorari to the United States Supreme Court, the union contended that the state court’s decision rested on a public policy against membership in the Communist Party in violation of the due process and equal protection clauses of the Fourteenth Amendment. Held, writ dismissed, three justices dissenting. Since the state court construed the agreement to mean that membership in the Communist Party is “just cause” for discharge, the decision can be sustained on adequate state grounds and there is no basis for review of constitutional questions. Black v. Cutter Laboratories, 351 U.S. 292 (1956).