Stringer v. National Football League
2007 U.S. Dist. LEXIS 7445, 474 F.Supp. 2d 894, 181 L.R.R.M. (BNA) 2588 (2007)
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Rule of Law:
A state-law tort claim is preempted by § 301 of the Labor Management Relations Act (LMRA) if its resolution is substantially dependent on or inextricably intertwined with the interpretation of a collective bargaining agreement (CBA). This preemption can apply even if the defendant is not a signatory to the CBA and the claim is based on a common law duty.
Facts:
- Korey Stringer was a professional football player for the Minnesota Vikings, a member club of the National Football League (NFL).
- In late July 2001, Stringer participated in the Vikings' mandatory summer training camp in Mankato, Minnesota.
- The NFL had previously issued 'Hot Weather Guidelines' as part of its Game Operations Manual.
- On July 30, 2001, during a practice in extreme heat and humidity, Stringer suffered from heat exhaustion.
- The next day, July 31, 2001, Stringer participated in another practice session, collapsed from heatstroke, and was hospitalized.
- Stringer was wearing football equipment, including a helmet and shoulder pads manufactured by Riddell, Inc.
- On August 1, 2001, Korey Stringer died from complications related to heatstroke.
Procedural Posture:
- Kelci Stringer, on behalf of Korey Stringer's estate, filed a wrongful death and products liability lawsuit in federal district court against the National Football League (NFL), NFL Properties, and Riddell, Inc.
- The claims against a team doctor and a claim for injunctive relief were voluntarily dismissed by the plaintiff.
- The NFL Defendants filed a motion to dismiss or, in the alternative, for summary judgment, arguing the remaining claims were preempted by § 301 of the LMRA.
- The Riddell Defendants filed a motion for judgment on the pleadings, also arguing for § 301 preemption.
- The U.S. District Court heard oral arguments on the motions.
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Issue:
Does § 301 of the Labor Management Relations Act (LMRA) preempt state-law tort claims related to a union employee's injury or death when resolving those claims requires interpretation of the Collective Bargaining Agreement (CBA)?
Opinions:
Majority - Holschuh, District Judge
Yes, § 301 of the LMRA preempts state-law tort claims when their resolution is inextricably intertwined with an interpretation of the Collective Bargaining Agreement (CBA), but does not preempt claims that can be resolved without interpreting the CBA. The court applied a two-step preemption analysis. First, it determined if the duty alleged arose from the CBA or state law. Second, if the duty arose from state law, it determined if resolving the claim required interpretation of the CBA. The negligence claim against the NFL for inadequate heat-illness policies (Count 1) was preempted because determining the NFL's standard of care required interpreting the CBA's provisions on the duties of team physicians and the certification of trainers to understand the baseline of care the teams were already contractually obligated to provide. However, the products liability claim against Riddell (Count 3) and the negligence claim against the NFL for approving unsafe equipment (Count 4) were not preempted because the CBA was largely silent on equipment safety standards, and resolving these claims did not require interpreting the CBA's terms.
Analysis:
This case clarifies the scope of LMRA § 301 preemption, particularly its application to non-signatories of a CBA and to common law tort claims. It establishes that even a claim based on an 'assumed duty' under common law can be preempted if the standard of care is defined by or dependent upon responsibilities allocated in the CBA. The decision distinguishes between claims that are 'inextricably intertwined' with a CBA and those that merely have a 'tangential relationship,' providing a framework for how future tort claims in unionized workplaces may survive or fail preemption. It underscores that plaintiffs must frame their claims based on duties wholly independent of the CBA to avoid federal preemption.
