Lingle v. Norge Div., Magic Chef, Inc. - 486 U.S. 399 (1988)
U.S. Supreme Court
Lingle v. Norge Div., Magic Chef, Inc., 486 U.S. 399 (1988)
Lingle v. Norge Division of Magic Chef, Inc.
Argued March 23, 1988
Decided June 6, 1988
486 U.S. 399
After petitioner notified her employer (respondent) that she had been injured in the course of her employment and requested compensation for her medical expenses pursuant to the Illinois Workers' Compensation Act, she was discharged for filing an allegedly false worker's compensation claim. The union representing petitioner filed a grievance pursuant to a collective bargaining agreement that protected employees from discharge except for "just" cause and that provided for arbitration of disputes between the employer and any employee concerning the effect or interpretation of the agreement. While arbitration was proceeding, petitioner filed a retaliatory discharge action in an Illinois state court, alleging that she had been discharged for exercising her rights under the Illinois worker's compensation laws. Respondent removed the suit to the Federal District Court on the basis of diversity of citizenship, and filed a motion to dismiss the case as preempted by § 301 of the Labor Management Relations Act of 1947. The court dismissed the complaint as preempted, concluding that the retaliatory discharge claim was "inextricably intertwined" with the collective bargaining provision prohibiting discharge without just cause, and that allowing the state law action to proceed would undermine the arbitration procedures in the collective bargaining contract. The Court of Appeals affirmed.
Held: Application of petitioner's state tort remedy was not preempted by § 301. An application of state law is preempted by § 301 only if such application requires the interpretation of a collective bargaining agreement. Pp. 486 U. S. 403-413.
(a) If the resolution of a state law claim depends upon the meaning of a collective bargaining agreement, the application of state law (which might lead to inconsistent results, since there could be as many state law principles as there are States) is preempted and federal labor law principles -- necessarily uniform throughout the Nation -- must be employed to resolve the dispute. Teamsters v. Lucas Flour Co., 369 U. S. 95; Allis-Chalmers Corp. v. Lueck, 471 U. S. 202. Pp. 486 U. S. 403-404.
(b) Under Illinois law governing the tort of retaliatory discharge for filing a worker's compensation claim, the employee must show both that he was discharged or threatened with discharge and that the employer's motive was to deter the employee from exercising rights under the
Workers' Compensation Act or to interfere with the exercise of those rights. Neither of those elements requires a court to interpret any term of a collective bargaining agreement. Similarly, the factual inquiry as to whether the employer had a nonretaliatory reason for the discharge does not turn on the meaning of any provision of a collective bargaining agreement. Although the state law analysis might involve attention to the same factual considerations as the contractual determination of whether petitioner was fired for just cause, such parallelism does not render the state law analysis dependent upon the contractual analysis. As long as the state law claim can be resolved without interpreting the collective bargaining agreement itself, the claim is "independent" of the agreement for § 301 preemption purposes. Pp. 486 U. S. 406-410.
(c) The result in this case is consistent both with the policy of fostering uniform, certain adjudication of disputes over the meaning of collective bargaining agreements and with cases that have permitted separate fonts of substantive rights to remain unpreempted by other federal labor law statutes. Interpretation of collective bargaining agreements remains firmly in the arbitral realm; judges can determine questions of state law involving labor-management relations only if such questions do not require construing collective bargaining agreements. There is nothing novel about recognizing that substantive rights in the labor relations context can exist without interpreting collective bargaining agreements. Pp. 486 U. S. 410-413.
823 F.2d 1031, reversed.
STEVENS, J., delivered the opinion for a unanimous Court.