Pruell v. Caritas Christi
645 F.3d 81
1st Cir.2011Background
- Pruell and Gordon filed a putative class action in Massachusetts Superior Court against Caritas hospital entities and executives over allegedly unpaid wages for meal breaks, pre/post-shift work, and training time.
- Claims are all state-law under Massachusetts wage and contract provisions, unjust enrichment, fraud, and related theories.
- Caritas removed the case to federal court invoking complete preemption under LMRA § 301 to preclude state claims.
- The district court dismissed primarily on preemption grounds after determining a CBA-related link; remand was denied.
- Judge’s central preemption question depended on whether named plaintiffs (and class members) are covered by CBAs; the court did not determine this coverage at the removal stage.
- On appeal, the First Circuit vacates and remands to determine if any named plaintiff is covered by a CBA and thus whether federal jurisdiction exists; if neither is covered, case should be remanded to state court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether removal was proper without clear CBA coverage of named plaintiffs | Pruell & Gordon contend state claims are independent and not preempted by LMRA | Caritas alleges CBAs cover plaintiffs; removal based on complete preemption | Subject matter jurisdiction in doubt; remand or limited discovery may be needed |
| Whether district court properly treated state claims as completely preempted | Claims can be adjudicated under state law without CBA interpretation | CBAs necessary to resolve underpayment and damages; preemption applies | Preemption cannot be resolved without establishing CBA coverage of named plaintiffs; remand advised to resolve jurisdiction first |
| Whether absent CBA coverage, the case should be remanded to state court | If no CBA covers named plaintiffs, removal was improper | If any CBA covers class members, removal stands | If no named plaintiff is covered by a CBA, remand to state court is appropriate |
| Whether limited discovery is warranted to determine CBA coverage | Limited discovery could ascertain CBA status | Discovery unnecessary; jurisdiction should be decided now | Limited discovery may be warranted to ascertain CBA coverage before remand or dismissal decision |
| Whether the case should be dismissed or remanded before addressing merits | Proceeding in state court if jurisdiction lacking | Federal court may dismiss or retain only if jurisdiction present | Remand or vacatur guided by jurisdiction over named plaintiffs and CBA status |
Key Cases Cited
- Textile Workers Union v. Lincoln Mills, 353 U.S. 448 (1957) (foundation of labor preemption doctrine)
- Allis-Chalmers Corp. v. Lueck, 471 U.S. 202 (1985) (interpretation vs. consultation of CBAs; preemption scope)
- Avco Corp. v. Aero Lodge No. 735, Intl. Ass'n of Machinists, 390 U.S. 557 (1968) (preemption and removal framework under §301)
- Exxon Mobil Corp. v. Allapattah Servs., Inc., 545 U.S. 546 (2005) (jurisdictional and statutory interpretation principles in federal-question cases)
- O'Donnell v. Boggs, 611 F.3d 50 (1st Cir. 2010) (de novo review of preemption and removal questions)
- BIW Deceived v. Local S6, Indus. Union of Marine & Shipbuilding Workers, 132 F.3d 824 (1st Cir. 1997) (removal/jurisdiction standards under LMRA)
- Denberg v. U.S. R.R. Ret. Bd., 696 F.2d 1193 (7th Cir. 1983) (jurisdictional reach of class actions when named-plaintiff jurisdiction is lacking)