LMRA § 301 provides exclusive federal jurisdiction for suits concerning "violation of contracts between an employer and a labor organization." 29 U.S.C. § 185(a). Similar to ERISA § 502(a), LMRA § 301 converts state causes of action into federal ones and allows removal "when the heart of the state-law complaint is a clause in the collective bargaining agreement." Caterpillar Inc. v. Williams, 482 U.S. 386, 394, 107 S.Ct. 2425, 96 L.Ed.2d 318 (1987) (quotation marks omitted). "[T]he pre-emptive force of § 301 is so powerful as to displace entirely any state cause of action for violation of contracts between an employer and a labor organization. Any such suit is purely a creature of federal law, notwithstanding the fact that state law would provide a cause of action in the absence of § 301." Franchise Tax Bd., 463 U.S. at 23, 103 S.Ct. 2841 (quotation marks and footnote omitted). NJ Carpenters v. Tishman Const., 760 F. 3d 297 (3d Cir. 2014).
LMRA § 301 completely preempts a state cause of action only when the resolution of said action is "substantially dependent upon analysis of the terms of an agreement made between the parties in a labor contract." Allis-Chalmers Corp. v. Lueck, 471 U.S. 202, 220, 105 S.Ct. 1904, 85 L.Ed.2d 206 (1985); see also Lingle v. Norge Div. of Magic Chef, Inc., 486 U.S. 399, 413, 108 S.Ct. 1877, 100 L.Ed.2d 410 (1988) ("[A]n 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."). By contrast, when resolution of the state law claim is "independent" of a CBA and does not require construing one, the state law claim is not preempted by § 301. Lingle, 486 U.S. at 410, 108 S.Ct. 1877; accord Antol v. Esposto, 100 F.3d 1111, 1117 (3d Cir.1996). NJ Carpenters v. Tishman Const., ibid..
THIS CASEBOOK contains a selection of 37 U. S. Court of Appeals decisions that analyze and interpret provisions of the Labor Management Relations Act. The selection of decisions spans from January 2010 to the date of publication.