482 U. S. 386
June 9, 1987
Several workers for Caterpillar were given contractual promises that the company would always provide them with work, even if they were laid off. At some point, due to cutbacks, these employees had to take lesser positions – ones that were covered by the collective bargaining agreement. Eventually, Caterpillar had to let these employees go completely, and the company did not line up new jobs for them, claiming that the collective bargaining agreement required no such thing. The employees sued in state court to enforce the original contracts. Caterpillar tried to get the case removed to federal court, arguing that all state suits involving collective bargaining agreements were preempted by the Labor Management Relations Act (LMRA).
Unanimously, the Court ruled that the state suit was not preempted. Brennan wrote that the suit did not involve the collective bargaining agreement, because in the original complaint, the employees relied only on their former individual contracts. That Caterpillar would use the later collective bargaining agreement as a legal defense did not matter. Jurisdiction law was written so as to make the plaintiff the master of the complaint. To allow a respondent to use an anticipated legal defense to drag a plaintiff into federal court would destroy this principle.
No surprise this was unanimous. The relevant law was pretty clear. Maybe I’m being uncharitable, but I can’t help feeling that unanimity would not have happened had the statutory text favored the company rather than the employees. Labor unions, much like criminal defendants, never seem to lose in the minds of Brennan and Marshall, regardless of what the relevant precedents and statutes seem to say.