Lingle v. Norge Div. of Magic Chef, Inc.

486 U. S. 399

June 6, 1988

A union worker was fired, ostensibly for filing a worker’s compensation claim. An Illinois law allowed the worker to receive extensive damages if the firing truly was retaliation for requesting worker’s compensation. The company responded that this state law was pre-empted by the Labor Management Relations Act (LMRA). The LMRA, as per Court precedent, preempts all state laws that require the interpretation of a collective bargaining agreement. Because the collective bargaining agreement defined “just cause” for firing, the company argued that the Illinois law must be preempted.

The Supreme Court unanimously disagreed. Stevens said that the Illinois courts were not required to refer to the collective bargaining agreement when considering the case. Because the Illinois courts could potentially find that the firing was unjust purely as a matter of state law, there was no need for preemption. Stevens emphasized that a few different precedents counseled strongly against finding preemption too easily. The Court’s legal holding was correct, but as always, I very much dislike as a public policy the federal regime of pampering unions.

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