Petitioner worked at respondent's Illinois plant and notified respondent that she had been injured on the job and sought benefits under the Illinois Workers' Compensation Act. Six days later, respondent discharged her for filing a "false worker's compensation claim." Her union filed a grievance under a collective-bargaining agreement that barred discharge except for proper or just cause and provided for arbitration, and an arbitrator ordered her reinstated with full backpay. Petitioner also brought an Illinois tort action alleging retaliatory discharge for exercising her workers' compensation rights.
Issue
Whether § 301 of the Labor Management Relations Act preempts an Illinois tort claim for retaliatory discharge when the employee is covered by a collective-bargaining agreement containing a just-cause provision and grievance-arbitration procedure. More specifically, the question is whether the state-law claim is preempted because it overlaps factually with a contractual just-cause dispute.
Rule
An application of state law is preempted by § 301 only if resolving the state-law claim requires interpretation of a collective-bargaining agreement. A state-law claim is not preempted merely because the same facts could also be relevant to a grievance or arbitration under a just-cause provision.
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Tara Nguyen worked at a unionized warehouse in Columbus, Ohio, under a collective-bargaining agreement allowing discharge only for just cause and requiring arbitration of grievances. After she filed a claim for state workers' compensation benefits, Riverbend Storage Co. fired her, stating that she had exaggerated her injury; Tara then sued in Ohio court under a state tort rule barring discharge motivated by an employee's pursuit of workers' compensation rights.
Is Tara's state-law claim most likely preempted by § 301 of the LMRA?
Explanation. § 301 preempts state law only when resolving the state-law claim requires interpretation of a collective-bargaining agreement. A retaliatory-discharge claim based on filing for workers' compensation typically asks whether the employee was discharged and whether the employer acted with a retaliatory motive—both factual inquiries. The mere existence of a just-cause clause and grievance procedure does not itself trigger preemption. Nonnegotiability alone is not the test.