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The dimensions of the Labor Management Relations Act of 1947, 29 U.S.C.S. § 185, require the conclusion that substantive principles of federal labor law must be paramount in the area covered by the statute.
The present action was brought by an employer against a union in the Superior Court of King County, Washington, for damages for business losses caused by a strike called by the union because of a dispute over the discharge of an employee, notwithstanding a clause in the collective labor contract between the parties providing that any difference arising between the employer and an employee should be submitted to arbitration and that the decision of the arbitrators should be final and binding. The court entered a judgment in favor of the employer, which, on appeal, was affirmed by Department One of the Supreme Court of Washington. In holding that the strike was a violation of the contract, the Washington Supreme Court expressly applied principles of state law. Certiorari was issued.
Should judgment be entered in favor of the employer, notwithstanding the fact that federal labor law pre-empted state law where a conflict existed?
The Supreme Court affirmed, holding that although federal labor law pre-empted state law where a conflict existed, affirmance was proper where petitioner violated the agreement despite the absence of a no-strike clause in the contract. According to the Court, the state court was not deprived of jurisdiction over the present litigation by 301(a) of the Labor Management Relations Act, which conferred like jurisdiction on Federal District Courts. The Court held that in actions under 301, substantive principles of federal labor law were paramount in the area covered by the statute. The Court held that a strike to settle a collective bargaining agreement violated the agreement because the agreement called for arbitration proceedings to settle disputes.