McNealy v. Caterpillar, Inc.

McNealy v. Caterpillar, Inc.

Opinion

 [*1115]  CUDAHY, Circuit Judge. This appeal is a small piece of one of the most protracted disputes between labor and management in recent history. Appellant Troy McNealy, a former member of the United Auto Workers (UAW), brought suit alleging that appellee Caterpillar violated Illinois law when it dismissed him without just cause. The district judge held that a prior decision of the Illinois Appellate Court precluded McNealy from pursuing his suit, and, in the alternative, that the National Labor Relations Act (NLRA) preempted McNealy's state law claim. In this opinion, we hold that the [**2]  decision of the Illinois court did not give rise to issue preclusion. We also find that McNealy and Caterpillar were not parties to an individual contract, and accordingly decline to reach whether the NLRA would preempt a state law claim based on breach of that contract. We conclude by suggesting that McNealy's claim would be more appropriately framed as a suit under § 301 of the NLRA.

I. Background

Troy McNealy was a production and maintenance employee at a Caterpillar plant from 1974 until he was involuntarily terminated in October 1992. In February 1991, McNealy went on short-term disability leave for foot surgery. Caterpillar extended this leave when McNealy manifested a form of epilepsy, and placed him on long-term disability leave in February 1992. But in October 1992, agents of Caterpillar saw McNealy driving an automobile. The company subsequently fired him for misrepresenting his medical condition. McNealy, who asserts that his illness does not prevent him from driving short distances, complained to his union, the UAW.

When Caterpillar fired McNealy, its employees were working without a formal collective bargaining agreement (CBA). That contract had expired in September [**3]  1991. Caterpillar and the UAW were unable to agree to the terms of a new CBA, and the UAW called a strike. After the UAW rejected three proposals by Caterpillar, the union and company had bargained to impasse. Eventually, Caterpillar notified the UAW that it would exercise its statutory right to unilaterally implement portions of its most recent contract proposal. On March 31, 1992, Caterpillar sent a letter to each UAW represented worker, including McNealy. The letter invited striking employees to return to work and summarized the unilaterally implemented terms.

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