Summary of a Recent
Judicial Development in
Labor

State Law Labor Claims Preempted by Federal Law

M. Sean Brister
National AgLaw Center Research Associate

Summary of Decision

In Murray v. Tyson Foods, Inc., No. 08-4001, 2009 WL 322241 (C.D. Ill. Feb. 9, 2009), the United States District Court for the Central District of Illinois granted Tyson's motion for partial summary judgment, dismissing the plaintiffs' state law claims and ruling that the state law claims were preempted by the Labor Management Relations Act (LMRA) of 1947 § 301(a), 29 U.S.C. § 185(a) (2006), because the state law claims hinged on the interpretation of a collective bargaining agreement governed by federal law.

Background

The plaintiffs were employees of Tyson at a pork processing facility in Illinois. Id. at *1. The plaintiffs alleged that Tyson failed to properly compensate them for time worked pursuant to the Illinois Minimum Wage Law (IMWL), the Illinois Wage Payment and Collection Act (IWPCA), and the Fair Labor Standards Act (FLSA). Id. Specifically at issue was whether the plaintiffs should be paid for time spent donning and removing sanitary equipment for the performance of their job duties. Id. at *3. In ruling on a prior motion to dismiss filed by Tyson, the court encouraged Tyson to file a motion for summary judgment based on the collective bargaining agreement (CBA) and preemption. Id. at *1. Tyson filed the instant motion seeking partial summary judgment pursuant to the court's encouragement. See id.

Arguments

The plaintiffs argued that Tyson failed to record all of their work time and that, had it been recorded, at least some of the plaintiffs would have been entitled to overtime pursuant to the IMWL. Id. at *3. The plaintiffs also argued that Tyson failed to pay them for all of their hours worked (specifically, time to don, remove, and sanitize equipment necessary for their work) in violation of the IWPCA. Id.

Tyson argued that determination of these claims relied on the definition of "work time" contained in the CBA and the terms of the CBA. Id. This requisite reliance on the CBA for the state law claims would thus lead to their preemption under the LMRA. Id. In response, the plaintiffs argued that Tyson's motion was premature and that discovery was necessary to determine whether a dispute in the language of the CBA existed. Id.

Analysis and Holdings

The court held that it would have to rely upon the CBA to determine the state law claims against Tyson, particularly the definition of "work time." Id. The court stated that this reliance on the CBA was sufficient to find that the state law claims were preempted by the federal LMRA to fulfill the intent of Congress to ensure that collective bargaining agreements are uniformly interpreted. See id. at *2, *4. The court stated that a dispute regarding interpretation of the CBA was not required, but that preemption would occur if the CBA was the subject of the dispute or the dispute was "substantially dependent upon an analysis of the terms of the CBA." Id. at *3.

The court then dismissed the plaintiffs' state law claims, finding that they had failed to exhaust the administrative remedies required by the CBA. Because no claims remained relative to a class action, the court ruled that the motions to certify a class and to stay class certification were moot. Id. at *4.

The case was decided on February 9, 2009.