The plaintiff worked for a railroad and belonged to a voluntary organization that provides relief for members (employees of railroads) when they are laid off or terminated (“held out of service”). The railroad terminated the plaintiff because of violating two rules of conduct: (1) no firearms on railroad property and (2) no dishonesty. The constitution of the voluntary organization provides that the organization pay benefits to its members when they are relieved of their usual duties, but that not when members are terminated for willful or intentional violations of job rules.
The plaintiff brought a firearm to work. When the railroad investigated this violation, the plaintiff offered contradictory explanations for his behavior. He told one investigator that he had accidentally brought the firearm to work; he told another investigator that he had brought the firearm to work to show fellow employees.
The railroad terminated the employee, who then applied for benefits from the voluntary organization. The voluntary organization denied the benefits because its board of directors decided that the plaintiff had acted intentionally. The organization's constitution provides that a member may appeal its decision to a court if the organization abuses its discretion in making a decision or certain procedural deadlines are not met, but provides no appeal may be had for the board's determining that an act is willful or intentional.
The Jefferson County Circuit Court ruled that the voluntary organization owed the plaintiff over $20,000 in benefits. The organization appealed this decision to the Alabama Court of Civil Appeals, which ruled that Alabama courts are required to turn a deaf ear to appeals from decisions by voluntarily organizations except when fraud, lack of jurisdiction, or arbitrary ruling are involved. The court ruled that when there is room for two opinions about the facts of a case, a decision is not arbitrary. Therefore, the decision of the circuit court was reversed. See Brotherhood's Relief and Compensation Fund v. Rafferty, decided on April 1, 2011.
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