Law School Case Brief
Caterpillar, Inc. v. Williams - 482 U.S. 386, 107 S. Ct. 2425 (1987)
Only state-court actions that originally could have been filed in federal court may be removed to federal court by the defendant. Absent diversity of citizenship, federal-question jurisdiction is required. The presence or absence of federal-question jurisdiction is governed by the well-pleaded complaint rule, which provides that federal jurisdiction exists only when a federal question is presented on the face of the plaintiff's properly pleaded complaint. The rule makes the plaintiff the master of the claim; he or she may avoid federal jurisdiction by exclusive reliance on state law.
Petitioner Caterpillar Tractor Co. ("Caterpillar") hired respondents Cecil Williams and several others (collectively, "Employees") to work at its San Leandro, California, facility in positions covered by its collective-bargaining agreement with a union. The Employees eventually assumed management and other positions outside the bargaining unit, and allegedly were repeatedly assured by Caterpillar that, if the San Leandro facility ever closed, Caterpillar would employ them at other facilities. Later, the Employees were downgraded to unionized positions, but allegedly they were assured that the downgrades were temporary. However, Caterpillar later notified them that its San Leandro plant would close and that they would be laid off. The Employees filed a lawsuit in California state court, alleging that Caterpillar breached the Employees' individual employment contracts. The complaint was based solely on state law. Caterpillar removed the action to federal district court, arguing that removal was proper because any individual employment contracts made with the Employees were, as a matter of federal substantive labor law, merged into and superseded by the collective-bargaining agreement. The Employees denied that they alleged any federal claim and sought remand of the action to the state court. The federal district court held that removal was proper, and dismissed the case when the Employees refused to amend the complaint to attempt to state a claim under § 301 of the Labor Management Relations Act, 1947, which conferred federal jurisdiction as to suits for violations of collective-bargaining agreements. The court of appeals reversed, holding that the case was improperly removed. Caterpillar was granted a writ of certiorari.
Were the Employees' claims removable to federal court?
The Supreme Court of the United States affirmed the appellate court's decision. The Court determined that the Employees' claims did not arise under the collective bargaining agreement and therefore did not arise under § 301 of the Labor Relations Act, 29 U.S.C.S. § 185. The Court ruled that the Employees' claims rested solely upon state law and thus the action was not removable to federal court.
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