1 F.4th 56
1st Cir.2021Background:
- Andrea Rose, an hourly member service representative at RTN Federal Credit Union, alleges unpaid compensation for extra travel time when periodically required to work at RTN's Dedham branch (longer commute).
- Rose sued in Massachusetts state court for unpaid wages, minimum wage, overtime, and payroll-records/pay-stub violations grounded in 454 Mass. Code Regs. 27.04(4)(b).
- RTN removed the case to federal court invoking complete preemption under §301 of the LMRA, arguing Rose's claims require interpretation of the collective bargaining agreement (CBA).
- The district court denied Rose's remand motion, concluded adjudication would require construing the CBA (including a temporary-transfer provision), and granted RTN judgment on the pleadings because Rose had not pursued the CBA grievance/arbitration process.
- Rose appealed; the First Circuit reviewed de novo and affirmed the district court, holding LMRA §301 preempted Rose's state-law claims and that the arbitration/grievance provision applied.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether §301 of the LMRA completely preempts Rose's state-law wage claims, permitting federal jurisdiction after removal | Rose: claims arise exclusively under state law and do not depend on CBA interpretation | RTN: claims are substantially dependent on, or require construction of, the CBA; §301 completely preempts them | Held: §301 preempts; federal jurisdiction proper (remand denied) |
| Whether resolving Rose's wage/overtime/record-keeping claims requires interpreting CBA provisions (e.g., temporary transfers, hours, overtime, classifications) | Rose: any CBA reference would be at most a bare consultation; no contract interpretation needed | RTN: merits turn on interpreting CBA provisions that affect compensable time and rate calculations | Held: adjudication requires CBA interpretation; claims fall within LMRA preemption |
| Whether the CBA's grievance/arbitration clause covers Rose's claims and mandates arbitration | Rose: clause doesn't encompass statutory wage claims or provide an adequate remedy | RTN: the clause is broadly worded to reach disputes over interpretation and remedies; arbitrators can fashion appropriate relief | Held: grievance clause covers these disputes; arbitration is appropriate and district court correctly entered judgment on pleadings |
| Whether removal was procedurally proper (remand motion) | Rose: motion to remand because no federal question exists | RTN: removal proper under complete-preemption doctrine | Held: remand denied; federal court had jurisdiction at time of removal |
Key Cases Cited
- Caterpillar Inc. v. Williams, 482 U.S. 386 (complete-preemption doctrine converts certain state claims into federal claims)
- Metropolitan Life Ins. Co. v. Taylor, 481 U.S. 58 (explaining the extraordinary pre-emptive force required for complete preemption)
- Allis-Chalmers Corp. v. Lueck, 471 U.S. 202 (LMRA §301 occupies field of labor-contract disputes; contract-based questions require federal law)
- Livadas v. Bradshaw, 512 U.S. 107 (distinguishing bare consultation of a CBA from claims requiring contract interpretation)
- Adames v. Executive Airlines, Inc., 258 F.3d 7 (1st Cir.) (claims for uncompensated time and benefits required CBA interpretation; preempted)
- Cavallaro v. UMass Memorial Healthcare, Inc., 678 F.3d 1 (1st Cir.) (wage claims depend on CBA provisions and thus fall within §301 preemption)
- Republic Steel Corp. v. Maddox, 379 U.S. 650 (federal labor policy requires use of contract grievance procedures for contract grievances)
- Steelworkers v. Enterprise Wheel & Car Corp., 363 U.S. 593 (arbitrators have broad authority to fashion remedies when CBAs are ambiguous or silent)