Spencer v. PeaceHealth
3:24-cv-05138
| W.D. Wash. | May 3, 2024Background
- Kathleen Spencer, a former PeaceHealth employee and union member, filed a wrongful termination claim in Washington state court, alleging she was fired in retaliation for using her rights under the collective bargaining agreement (CBA).
- Spencer claimed PeaceHealth failed to provide sufficient notice her job was being eliminated and retaliated against her for exercising rights under the CBA.
- PeaceHealth removed the case to federal court, arguing the claim was governed by federal labor law and preempted by Section 301 of the Labor Management Relations Act (LMRA).
- PeaceHealth moved to dismiss the complaint for failure to state a claim, asserting the claim was preempted and that Spencer failed to exhaust CBA grievance procedures.
- Spencer argued her claim arose independently under Washington law and public policy, not the CBA, and sought remand back to state court.
- The district court considered the parties’ arguments and determined it lacked federal jurisdiction, remanding the case to state court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether claim is preempted by Section 301 of the LMRA | Right exists independently of CBA, based on state law | Claim arises from rights under CBA, thus preempted | Not preempted; arises under state law |
| Whether the claim substantially depends on interpretation of the CBA | No CBA provision needs interpretation, purely factual | Must interpret CBA provisions on grievance/layoff | No substantial dependence found |
| Whether federal court has subject matter jurisdiction | No federal claim; should be remanded | Federal claim under LMRA; proper jurisdiction | No jurisdiction; remand to state court |
| Attorney’s fees on remand | Requested—removal unreasonable | Removal had valid legal arguments | Request denied; removal not objectively unreasonable |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (sets the standard for plausibility in pleadings under Rule 12(b)(6))
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (establishes pleading standard for a claim to survive a motion to dismiss)
- Allis-Chalmers Corp. v. Lueck, 471 U.S. 202 (1985) (§ 301 LMRA preempts state law claims requiring interpretation of a CBA)
- Smith v. Bates Tech. Coll., 139 Wn. 2d 793 (Wash. 2000) (Washington law protects wrongful termination for exercising legal rights as a matter of public policy)
- Garcia v. Serv. Emps. Int’l Union, 993 F.3d 757 (9th Cir. 2021) (§ 301 only preempts when interpretation of disputed CBA terms is required)