United Mine Workers of America v. Lockridge

Supreme Court of the United States · 1971 · Labor Law

Labor LawNLRA preemptionUnion-member disputesUnion security clausesNLRApreemptionGarmonGonzales

Facts

Lockridge was a bus driver employed by Greyhound and a member of the union, and the collective-bargaining agreement required covered employees to become and remain union members as a condition of employment. After Lockridge was released from dues checkoff, the local union treasurer suspended him and asked Greyhound to discharge him because he had not paid October dues; Greyhound did so, and the union later refused a tender of October and November dues. Idaho courts concluded that under the union's rules Lockridge had not yet suspended himself from membership, so the union breached a contractual obligation by causing his discharge. No charge was filed by Lockridge with the NLRB, and he instead pursued relief in state court.

Issue

Whether the National Labor Relations Act preempts state-court jurisdiction over a union member's state-law contract action against his union when the challenged conduct is the union's procurement of his discharge under a union-security arrangement and that conduct is arguably protected or prohibited by Sections 7 or 8 of the Act. Also, whether this case falls within any exception for purely internal union matters, Section 301 contract suits, or duty of fair representation claims.

Rule

Under Garmon, state and federal courts must yield when the conduct a State seeks to regulate is arguably protected by Section 7 or prohibited by Section 8 of the NLRA. Preemption turns on the conduct being regulated, not on the label attached to the claim or the use of general state contract law. Gonzales survives only for suits focused on purely internal union matters; it does not permit state regulation of disputes centered on procurement of discharge from employment. Exceptions exist where Congress affirmatively authorized judicial power, where deeply rooted local interests are involved, or where a properly defined fair-representation claim is proved, but a fair-representation claim requires arbitrary or bad-faith conduct and substantial evidence of fraud, deceitful action, or dishonest conduct.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Columbus, Ohio, Nora Patel works for Rivergate Transit Co. under a collective-bargaining agreement containing a valid union-security clause. Her union tells the employer to terminate her because, under the union constitution, she supposedly lost membership after failing to pay an assessment that the union treated as equivalent to dues; Nora sues the union in Ohio state court for breach of the union constitution and seeks lost wages.

Is the state-court action most likely preempted?

Explanation. Under the majority rule, preemption turns on the conduct the state seeks to regulate, not the formal label attached to the claim. A state-law contract suit is preempted when it targets union conduct in causing an employer to discharge an employee under a union-security arrangement, because that conduct is at least arguably prohibited by Sections 8(b)(1)(A), 8(b)(2), or implicates Section 8(a)(3).