Lingle v. Norge Div. of Magic Chef - 486 U.S. 399, 108 S. Ct. 1877 (1988)

Rule:

An application of state law is preempted by § 301 of the Labor Management Relations Act of 1947, 29 U.S.C.S. § 185(a), only if such application requires the interpretation of a collective-bargaining agreement.

Facts:

The union representing petitioner filed a grievance under its collective bargaining agreement with respondent, petitioner's employer, alleging that petitioner was discharged without just cause after she requested workers' compensation. Petitioner also brought a tort action under state law for retaliatory discharge, which was dismissed by the lower courts, which held that it was pre-empted by § 301(a) of the Labor Management Relations Act of 1947, 29 U.S.C.S. § 185(a). The United States Court of Appeals for the Seventh Circuit affirmed the dismissal of the petitioner’s state tort claim against her employer. Petitioner challenged the decision. 

Issue:

Was the petitioner’s claim pre-empted by § 301(a) of the Labor Management Relations Act of 1947, 29 U.S.C.S. § 185(a)? 

Answer:

No.

Conclusion:

The court granted certiorari and reversed the decision, holding that petitioner's claim was not pre-empted because it was independent of the collective bargaining agreement. While the state law analysis might have involved the same facts as the contractual determination of whether petitioner was fired for just cause, resolution of the state claim did not require construing the collective-bargaining agreement. The success of petitioner's state claim would have depended upon whether respondent could show a non-retaliatory reason for her discharge; a purely factual inquiry which did not turn on the meaning of any provision of the collective bargaining agreement.