Subject matter jurisdiction
Federal courts lack jurisdiction over a state wage claim dispute, even though a collective bargaining agreement permits the allegedly unlawful practice.
“[A]lthough federal law would govern any interpretation of the collective bargaining agreement that a state court might need to make in the course of determining plaintiffs’ damages, the need to make such an interpretation does not mean that plaintiffs’ state-law claims are preempted. Indeed, state courts are allowed to interpret collective bargaining agreements, provided they apply federal rather than state law when doing so, Teamsters v. Lucas Flour Co., 369 U.S. 95, 102 (1962); Charles Dowd Box Co. v. Courtney, 368 U.S. 502 (1962), and so the need for a state court to interpret the collective bargaining agreement in the course of calculating plaintiffs’ damages under state law poses no threat to the uniformity of federal labor law and would not ‘frustrate the federal labor-contract scheme established in § 301.’ Allis-Chalmers, 471 U.S. at 209. There is therefore no reason to find plaintiffs’ state-law claims preempted, and plaintiffs have not defeated their own claims by trying to use preemption as a basis for federal jurisdiction under § 301.”
11-C0171 Williams v. C&D Technologies, Inc.
E.D.Wis., Adelman, J.