Watts v. United Parcel Service, Inc.
701 F.3d 188
6th Cir.2012Background
- Watts, a UPS employee since 1990 in Ohio, suffered a serious back injury in 2000 and received Temporary Total Disability benefits.
- Watts was released to light-duty in November 2002 amid a UPS light-duty program (TAW) she sought to join but was rejected, with dispute over disability-based denial.
- Watts’s treating physician found she reached maximum medical improvement in July 2002; UPS terminated TTD payments in November 2002.
- Watts filed a federal ADA claim; after multiple trials and appeals, UPS moved for judgment as a matter of law on the ADA claim on the basis of LMRA §301 preemption and a six-month limitations period.
- The district court dismissed Watts’s ADA claim as preempted and time-barred under §301; the Sixth Circuit reversed on preemption, remanding for trial on the ADA claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does § 301 LMRA preempt the ADA claim when brought in federal court? | Watts's ADA claim is independent of the CBA and does not require interpretation of the CBA. | Watts’s ADA claim requires interpretation of the CBA, thus preempted by § 301. | No preemption: ADA claim is independent of the CBA and not precluded by § 301. |
| Whether § 301’s six-month limitations apply to Watts’s ADA claim in federal court? | The six-month LMRA limitations do not govern an independent ADA claim. | LMRA limitations apply to § 301 actions that preempt state/federal claims tied to the CBA. | Not dispositive here; the ADA claim is not preempted and is separate from § 301. |
| Is Watts’s ADA claim independent of the CBA rather than a contract-based claim under the LMRA? | ADA creates a separate federal right; not dependent on the CBA. | CBA could inform Watts’s remedies under the LMRA. | ADA claim is independent and not grounded in the CBA. |
Key Cases Cited
- Teamsters v. Lucas Flour Co., 369 U.S. 95 (1962) (preemption of CBA interpretation to ensure uniform federal labor-law application)
- Allis-Chalmers Corp. v. Lueck, 471 U.S. 202 (1985) (uniform interpretation of contract terms across jurisdictions for CBAs)
- Lingle v. Norge Div. of Magic Chef, Inc., 486 U.S. 399 (1988) (not every dispute involving a CBA is preempted; independence of non-interpreting claims)
- O’Shea v. Detroit News, 887 F.2d 683 (6th Cir. 1989) (statements on preemption discussed; dicta on scope related to state-law claims)
- Martin v. Lake County Sewer Co., 269 F.3d 673 (6th Cir. 2001) (distinguishes contract-based claims under CBA from independent statutory claims)