Matson v. United Parcel Service, Inc.

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Plaintiff filed suit against her employer, UPS, alleging a state law gender-based hostile work environment claim. A jury returned a verdict for plaintiff on that claim, but the district court granted UPS's motion for a new trial on the ground that the claim was preempted under section 301 of the Labor Management Relations Act (LMRA), 29 U.S.C. 185(a). The jury in the second trial found for UPS. The court concluded that the district court erred in holding plaintiff's claim preempted. The court fashioned a two-part test to determine whether a state law claim is preempted under section 301. At the first step, the court asks “whether a particular right inheres in state law or, instead, is grounded in a CBA.” Only if the claim is “founded directly on rights created by collective-bargaining agreements” is preemption warranted at this step. At step two, “to determine whether a state law right is ‘substantially dependent’ on the terms of a CBA,” the court asks “whether the claim can be resolved by ‘look[ing] to’ versus interpreting the CBA.” In this case, the jury did not have to decide what any provision of the CBA requires. Therefore, the court reversed the district court's conclusion that plaintiff's claims were preempted to the extent they relied on her allegations regarding UPS’s extra work assignments, and reinstated the jury verdict from the first trial. The court also reversed the district court’s conclusion that the jury’s damages award was “grossly excessive” and remanded for reconsideration. View "Matson v. United Parcel Service, Inc." on Justia Law