Background - Plaintiff George Melendez, a union security guard at AT&T Park since 2005, sued the Giants for failing to pay final wages immediately under Cal. Labor Code §201 after what he alleges are intermittent terminations at the end of games, homestands, seasons, or events. - Melendez and other guards are covered by a Collective Bargaining Agreement (CBA) between the Giants and SEIU/United Service Workers West; employment classifications (regular, seasonal, senior/super senior) are based on annual hours. - The CBA requires pre-hire screening, defines probationary periods, provides scheduling discretion to the Giants, limits discharge to for-cause terminations, and contemplates year-to-year duration. - The Giants argued guards remain employed between events under the CBA (not discharged after each event) and moved to compel arbitration under the CBA and to dismiss as preempted by §301 of the Labor Management Relations Act. - The trial court denied the motion to compel arbitration; the Court of Appeal reversed on §301 preemption grounds, holding resolution requires interpretation of the CBA and therefore the dispute must be arbitrated under federal law. ### Issues | Issue | Plaintiff's Argument | Defendant's Argument | Held | |---|---:|---:|---:| | Whether the dispute falls within the CBA's arbitration clause | Melendez: claim is statutory under Lab. Code §201; does not require CBA interpretation (L'Oreal controls). | Giants: employment terms are set by the CBA; dispute about whether guards are "discharged" depends on CBA and thus is arbitrable. | Court: Not within the CBA's contractual arbitration clause on its face, but federal §301 preemption requires arbitration because resolving the §201 issue necessarily depends on interpreting the CBA. | | Whether Labor Code §201 claim is preempted by §301 LMRA | Melendez: §201 is a state-law statutory claim that can be decided without interpreting the CBA. | Giants: determining if guards were "discharged" requires analyzing employment duration and terms under the CBA. | Court: §301 preemption applies because resolution "substantially depends" on analysis of the CBA; therefore federal law governs and grievance/arbitration procedures apply. | | Applicability of Smith v. Superior Court (L'Oreal) | Melendez: L'Oreal means completion of a specific assignment can constitute a discharge triggering §201. | Giants: L'Oreal is distinguishable because guards here are covered by a CBA that implies ongoing employment beyond single assignments. | Court: L'Oreal requires first determining the parties' agreed employment term; here that requires interpreting the CBA, so L'Oreal does not avoid preemption. | | Whether CBA language must be specifically construed to resolve the claim | Melendez: no specific CBA clause must be interpreted; only factual determination whether termination occurred. | Giants: numerous CBA provisions (classification by annual hours, probation, discharge-for-cause, holiday pay, pre-hire screening) inform employment duration and require interpretation. | Court: Even if no single provision is dispositive, resolving whether guards were discharged requires construing the CBA as a whole; arbitration required. | ### Key Cases Cited Smith v. Superior Court (L'Oreal), 39 Cal.4th 77 (2006) (completion of a particular assignment can constitute a statutory "discharge" under Cal. Labor Code §201). Livadas v. Bradshaw, 512 U.S. 107 (1994) (§301 does not preempt state-law claims when resolution does not require interpretation of the CBA). Newberry v. Pacific Racing Assn., 854 F.2d 1142 (9th Cir. 1988) (preemption applies when state-law application requires interpretation or substantial analysis of CBA terms). Levy v. Skywalker Sound, 108 Cal.App.4th 753 (2003) (summary of §301 preemption principles; claim preempted if resolution requires interpreting the CBA). Balcorta v. Twentieth Century-Fox Film Corp., 208 F.3d 1102 (9th Cir. 2000) (no preemption where a discharge determination did not require interpreting the CBA). Flores v. Axxis Network & Telecommunications, Inc., 173 Cal.App.4th 802 (2009) (arbitration clause scope requires the dispute to be a grievance under the CBA to compel contractual arbitration).