Healy v. Metro. Pier & Exposition Auth.

Plaintiffs, a putative class of electrical workers, claimed that their respective employers, in collusion with Metropolitan Pier and Exposition Authority (MPEA, which used electricians supplied by the employers) wrongfully terminated them, in violation of a collective bargaining agreement (CBA) and federal labor law and circumvented the CBA-mandated hiring process and that their union, International Brotherhood of Electrical Workers, failed to adequately represent them in the CBA-mandated grievance process. The district court denied motions to dismiss four counts, but dismissed a declaratory judgment motion against MPEA and two employers, and the claim of state law tortious interference with contracts against MPEA. The district court held that, as a political subdivision, MPEA is not an “employer” under Section 301 of the Labor Management Relations Act of 1947, 29 U.S.C. 185. Plaintiffs appealed only the dismissal of the tortious interference claim against MPEA. The Seventh Circuit affirmed, rejecting an argument that jurisdiction was created by the need to interpret the CBA. With respect to political subdivisions, section 301 preempts not only claims “founded directly” on the collective bargaining agreement, but also state law claims that indirectly implicate a collective bargaining agreement. View "Healy v. Metro. Pier & Exposition Auth." on Justia Law