No specific laws identified for this ruling.
The Second Circuit affirmed the district court's dismissal of Commer's complaint under Rule 12(b)(6). All claims were dismissed, including LMRDA Section 501 claims against the labor organization and individual members, LMRA Section 301 claims on collateral estoppel grounds, NLRA Section 8 claims for lack of jurisdiction, and LMRDA Section 101(a)(2) claims as duplicative of a pending action.
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