481 U. S. 851
May 26, 1987
Sally Hechler was injured on the job, and sought to sue her union, the International Brotherhood of Electrical Workers (IBEW), for negligently failing to make sure that her employer provided her with safe employment. The Labor Management Relations Act (LMRA) says that any state law claim which requires interpretation of a collective bargaining agreement is preempted by federal law. Hechler tried to argue that her claim did not involve contract interpretation, and was based purely on non-contract negligence.
The Court unanimously concluded that Hechler’s complaint necessarily involved her collective bargaining agreement, and that her state suit was thus preempted by federal law. Blackmun wrote for the Court, explaining that this law was passed in order to provide for uniform national interpretations of collective bargaining agreements. Under traditional tort law, only employers could be liable for negligence claims, so any attempt to sue her union had to rest on some contractual arrangement. Indeed, her original complaint referred indirectly to the collective bargaining contract. Because it was unclear whether the applicable federal claim could even be heard any longer due to the statute of limitations deadline, Blackmun remanded the case. Stevens dissented from that last holding, finding that the deadline for the relevant claim had definitely passed.
Based on the apposite law, this was clearly the correct ruling. As is often the case in preemption cases though, I’m not entirely sure whether Congress really had the Article I authority to pass the LMRA. Regardless, I am disgusted by the cynicism and hypocrisy of the IBEW. Just eight days ago, the Court supported that very union’s right to fine members who worked for employers without collective bargaining agreements. Here, the union is trying to get out of having to abide by the collective bargaining agreement it made. Kind of belies the idea that the union truly cares about the welfare of the workingman and not just its own self-interest, doesn’t it?