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Lingle v. Norge Division of Magic Chef, Inc.

Supreme Court of United States
486 U.S. 399 (1988)
ELI5:

Rule of Law:

An application of state law is pre-empted by § 301 of the Labor Management Relations Act of 1947 only if such application requires the interpretation of a collective-bargaining agreement.


Facts:

  • Jonna Lingle was an employee at a manufacturing plant operated by Norge Division of Magic Chef, Inc. and was covered by a collective-bargaining agreement (CBA).
  • On December 5, 1984, Lingle was injured in the course of her employment and notified Norge.
  • Lingle requested compensation for her medical expenses pursuant to the Illinois Workers’ Compensation Act.
  • On December 11, 1984, Norge discharged Lingle for allegedly filing a 'false worker’s compensation claim.'
  • The CBA covering Lingle protected employees from discharge except for 'just cause' and provided for a grievance and arbitration procedure to resolve disputes.
  • The union representing Lingle filed a grievance on her behalf, which ultimately resulted in an arbitrator ordering her reinstatement with full backpay.

Procedural Posture:

  • Jonna Lingle filed a complaint against Norge Division of Magic Chef, Inc. in the Illinois Circuit Court for Williamson County, a state trial court.
  • Norge removed the case to the U.S. District Court for the Southern District of Illinois based on diversity of citizenship.
  • Norge filed a motion to dismiss the case, arguing that Lingle's state-law claim was pre-empted by § 301 of the Labor Management Relations Act.
  • The District Court granted the motion to dismiss, holding that the claim was 'inextricably intertwined' with the collective-bargaining agreement.
  • Lingle appealed to the U.S. Court of Appeals for the Seventh Circuit.
  • The Court of Appeals, sitting en banc, affirmed the District Court's dismissal.
  • The U.S. Supreme Court granted certiorari to resolve a conflict among the circuit courts on this issue.

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Issue:

Does § 301 of the Labor Management Relations Act pre-empt an employee's state-law tort claim for retaliatory discharge when the employee is covered by a collective-bargaining agreement that provides a contractual remedy for discharge without just cause?


Opinions:

Majority - Justice Stevens

No. An application of state law is pre-empted by § 301 of the Labor Management Relations Act only if such application requires the interpretation of a collective-bargaining agreement. To prove the Illinois state tort of retaliatory discharge, Lingle must show she was discharged and that the employer's motive was to deter her from exercising her rights under the Workers' Compensation Act. These are purely factual questions pertaining to the employee's conduct and the employer's motivation; neither element requires a court to interpret any term of the collective-bargaining agreement. Even if the state-law analysis involves attention to the same factual considerations as a contractual determination of 'just cause,' such parallelism does not render the state-law analysis dependent on the contract. As long as the state-law claim can be resolved without interpreting the agreement itself, the claim is 'independent' of the agreement for § 301 pre-emption purposes and may proceed.



Analysis:

This decision significantly clarifies the scope of § 301 pre-emption, establishing a clear and narrow test focused solely on whether a state-law claim requires interpretation of a collective-bargaining agreement (CBA). It ensures that unionized employees are not forced to forfeit substantive rights granted by state law, such as protections against retaliatory discharge, simply because their CBA provides a parallel remedy. The ruling preserves the state's traditional police power to establish minimum labor standards while upholding the federal interest in having arbitrators, not courts, provide uniform interpretations of labor contracts. Future pre-emption analyses will now hinge on this 'interpretive' test rather than on whether the state claim and a CBA grievance involve the same set of facts.

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