CORIZON HEALTH, INC. v. WHITEHEAD, 2:17-cv-01807

Corizon Health sued former nurse John Whitehead in Pennsylvania state court seeking reimbursement of $28,710.62 it alleges was mistakenly overpaid in wages and shift differentials.
Corizon pleaded breach of contract and unjust enrichment, alleging the employment terms limited overtime to hours over 40 per week.
Whitehead removed the case to federal court, asserting federal-question jurisdiction because Corizon’s claims are preempted by the Labor Management Relations Act (LMRA) and would require interpretation of the parties’ collective bargaining agreement (CBA).
Whitehead also filed a motion to dismiss claiming LMRA preemption; Corizon moved to remand for lack of federal subject-matter jurisdiction.
The district court examined whether resolution of Corizon’s purely state-law restitution and contract claims would necessarily require interpreting the CBA and thus be preempted under section 301 of the LMRA.
The court concluded the claims are independent of the CBA, do not require its interpretation, and therefore remanded the case to state court; Whitehead’s motion to dismiss was denied as moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether federal subject-matter jurisdiction exists via LMRA (§301) preemption	Corizon: state-law restitution and contract claims do not depend on CBA interpretation and thus belong in state court	Whitehead: Corizon’s claims are preempted because adjudication will require interpreting the CBA (grievance procedures, pay codes)	No federal jurisdiction; claims not preempted and case remanded to state court

Kokkonen v. Guardian Life Co. of Am., 511 U.S. 375 (federal courts are courts of limited jurisdiction)
Caterpillar Inc. v. Williams, 482 U.S. 386 (well-pleaded complaint rule; state-law claims arise under federal law only if they necessarily depend on substantial federal question)
Franchise Tax Bd. v. Constr. Laborers Vacation Trust, 463 U.S. 1 (complete preemption doctrine)
Textile Workers Union of Am. v. Lincoln Mills, 353 U.S. 448 (§301 authorizes federal courts to enforce collective-bargaining agreements)
Allis-Chalmers Corp. v. Lueck, 471 U.S. 202 (state-law claims preempted when substantially dependent on CBA analysis)
Lingle v. Norge Div. of Magic Chef, Inc., 486 U.S. 399 (state-law claim not preempted if it can be resolved without interpreting the CBA)
Antol v. Esposto, 100 F.3d 1111 (3d Cir. standard for independence from CBA)
Abels v. State Farm Fire & Cas. Co., 770 F.2d 26 (removal statute strictly construed; doubts resolved for remand)