Section 301\u27s Preemption of State Law Claims: A Model For Analysis

Congress, in section 301(a) of the Labor Management Relations Act, has provided a cause of action for breach of a collective bargaining agreement. This statute has long been interpreted as ousting state law claims for breach of contract when the contract involved is a collective bargaining agreement. To what extent Congress, in enacting section 301, intended to foreclose other state law claims by the parties to or the individuals covered by a collective bargaining agreement is an issue that has recently gained prominence. The Supreme Court has decided four such cases unanimously in the last four years. Such contemporary and concordant direction from the high Court could well be expected to have eliminated confusion in the courts below. The decisions, however, have increased the uncertainty in the lower courts, due perhaps to what initially appear as inconsistencies in the Court\u27s approach. This Article proposes an analysis, drawn from the Court\u27s recent decisions, that enables the decisions to be read as a coherent whole. As this Article demonstrates, a careful reading of the opinions reveals a clear framework for resolving section 301 preemption issues. This framework directs the preemption of all but a narrow class of state law claims