Kitzmann v. Local 619-M Graphic Communications Conference of the International Brotherhood of Teamsters
415 F. App'x 714
| 6th Cir. | 2011Background
- Kitzmann was the compensated president of Local 619-M for a three-year term ending 2006.
- Affiliation discussions with District Council 3 led to an affiliation agreement that ended Kitzmann’s compensation.
- The affiliation agreement provided that DC 3 constitution would supersede Local 619’s, and Local 619 would have no employees.
- Kitzmann learned of the referendum, attempted to destroy ballots, but the referendum passed and the affiliation proceeded.
- Kitzmann filed suit in Kentucky state court; defendants removed it to federal court, and after discovery both sides moved for summary judgment.
- The district court held § 301 LMRA preemption supported jurisdiction and granted summary judgment for defendants; on appeal, the court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether §301 preemption supports removal/jurisdiction | Kitzmann argues not all claims are preempted | Defendants maintain the claims are preempted by §301 | Yes; at least some claims are preempted and federal jurisdiction existed |
| What test governs §301 preemption in this case | Complaint-based approach; not all claims rely on labor-contract analysis | Two-step Caterpillar/Mattis framework applies | Court applies the two-step test for §301 preemption |
| Are Counts I–IV preempted as contracts between labor organizations | Declarations against referendum validity and process are not §301 contracts | Counts I–IV allege breaches of contracts between labor organizations | Yes; Counts I–IV preempted under §301; Counts V–VII fall within supplemental jurisdiction |
| Was the district court’s merits ruling proper | Contract terms supported ongoing compensation | Affiliation ended compensation per contract | Argument waived on appeal; merits affirmed by district court |
Key Cases Cited
- Beneficial Nat’l Bank v. Anderson, 539 U.S. 1 (U.S. 2003) (complete preemption by § 301)
- Caterpillar Inc. v. Williams, 482 U.S. 386 (U.S. 1987) (well-pleaded complaint rule for federal question jurisdiction)
- Allis-Chalmers Corp. v. Lueck, 471 U.S. 202 (U.S. 1985) (§ 301 preemption scope and labor-contract interpretation)
- Wooddell v. Int’l Bhd. of Elec. Workers, Local 71, 502 U.S. 93 (U.S. 1991) (union constitutions as contracts under § 301)
- Mattis v. Massman, 355 F.3d 902 (6th Cir. 2004) (two-step preemption test under § 301)
- Loftis v. United Parcel Serv., Inc., 342 F.3d 509 (6th Cir. 2003) (complete preemption framework under § 301)
- Textron Lycoming Reciprocating Engine Division, Avco Corp. v. UAW, 523 U.S. 653 (U.S. 1998) (context for § 301 preemption)