Law School Case Brief
Williams v. Aona - 121 Haw. 1, 210 P.3d 501 (2009)
The doctrine of exhaustion is not absolute. Exceptions to the doctrine exist, such as when pursuing a contractual remedy would be futile. Likewise, an aggrieved party need not exhaust administrative remedies where no effective remedies exist. For purposes of the exhaustion requirement, a court must determine whether an employee's claims arise from the terms of a collective bargaining agreement (CBA). In order to determine whether the claims arise from the terms of the CBA, the court must look to the relevant CBA provisions.
Respondent Robert Aona and petitioner Cedric Williams were employees of the City and County of Honolulu Department of Environmental Services ("City"). Williams filed a petition for an Ex Parte Temporary Restraining Order and for Injunction Against Harassment against Aona in Hawaii state court. The petition was based on recent or past acts of harassment. Williams testified that after Aona palmed him, he felt "a sharp pain" in his chest and noticed "a mark" on his chest. The district court granted the petition for injunction. The district court found that Williams had established by celar and convincing evidence that Aona had harassed him within the meaning of the Hawaii Revised Statutes. On Aona's appeal, the intermediate court of appeals affirmed the district court. Aona filed a petition for writ of certiorari to review the appellate court's judgment. Aona argued that the appellate court incorrectly held that the district court had jurisdiction over Williams' petition for an injunction. Aona argued that Williams should have waited for the results of the workplace investigation into the grievance he filed against Aona before filing his petition with the district court. The state supreme court granted certiorari.
Did the district court properly exercise jurisdiction over Williams' petition?
The state supreme court vacated the appellate court's judgment as to the issue of preemption and affirmed the district court's order granting Williams' petition for injunctive relief. The court found that the appellate court erroneously analyzed the issue of the district court's jurisdiction because the doctrine of preemption was inapplicable. The district court was not presented with conflicting state and federal statutes because the National Labor Relations Act ("NLRA") did not apply to the City. The NLRA only applied to "employers," as defined by the NLRA. Aona and Williams' employer, the City, was a political subdivision of the State of Hawaii, and therefore, the NLRA did not apply. However, the court ruled, although the appellate court used an erroneous framework to determine that the district court had jurisdiction over the Williams' petition, the appellate court correctly concluded that the district court had jurisdiction because the petition involved conduct outside the scope of the collective bargaining agreement (CBA). Even if CBA remedies did apply, tort claims were excepted from the general rule that employees had to exhaust their remedies under the CBA before seeking judicial relief. The CBA did not provide Williams with an adequate remedy. Moreover, public policy did not support limiting injunctions against harassment for employees subject to CBAs. Thus, Williams was not required to exhaust his contractual remedies before filing the petition for injunctive relief.
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