William Jackson v. US Steel Corporation
18-12191
| 11th Cir. | Feb 22, 2019Background
- William Jackson, chair of his union's grievance committee at U.S. Steel, sought to invoke a collective-bargaining agreement (CBA) "superseniority" provision during layoffs.
- Jackson alleges U.S. Steel and Union Steel conspired to defame him by circulating statements that he misused his union position and engaged in criminal conduct; he filed unfair labor practice charges with the NLRB, which were dismissed on administrative appeal.
- Jackson sued in Alabama state court for defamation, invasion of privacy, negligence, wantonness, and intentional infliction of emotional distress (IIED) based on those published statements.
- Defendants removed to federal court, arguing complete preemption under LMRA § 301; the district court dismissed the complaint and denied remand.
- On appeal, the Eleventh Circuit reviewed de novo whether § 301 preempted Jackson’s state-law tort claims and affirmed dismissal and denial of remand.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether state-law tort claims are preempted by LMRA § 301 | Jackson contends his claims are ordinary state torts and not dependent on CBA interpretation | Defendants contend resolution requires interpreting CBA rights (superseniority) and duties, so § 301 preempts | Preempted: claims require interpretation of the CBA and are completely preempted under § 301 |
| Whether falsity element of defamation/privacy can be decided without CBA reference | Jackson argues falsity can be determined from statements alone | Defendants argue falsity hinges on whether Jackson was entitled to superseniority under the CBA | Preempted: falsity requires analyzing CBA entitlement, so claims are inextricably intertwined with CBA |
| Whether negligence/wantonness claims can stand independently of defamation and CBA issues | Jackson asserts duties not to harm him exist independently as tort duties | Defendants assert alleged duties arise from or duplicate CBA-based duties (e.g., confidentiality, representation) | Preempted: adjudication would require interpreting CBA duties or would duplicate preempted defamation claims |
| Whether IIED claim is independently actionable without CBA interpretation | Jackson argues conduct was extreme and outrageous independent of the CBA | Defendants argue alleged IIED conduct (publishing allegedly false statements) requires assessing propriety under the CBA | Preempted: IIED here depends on CBA interpretation; not shown to be extreme without CBA reference |
Key Cases Cited
- Am. Dental Ass'n v. Cigna Corp., 605 F.3d 1283 (11th Cir. 2010) (standard of review for dismissal and § 301 preemption analysis)
- Atwater v. Nat'l Football League Players Ass'n, 626 F.3d 1170 (11th Cir. 2010) (§ 301 preemption applies where duties alleged arise from CBA)
- Bartholomew v. AGL Res., Inc., 361 F.3d 1333 (11th Cir. 2004) (§ 301 grants federal jurisdiction over CBA disputes)
- Lingle v. Norge Div. of Magic Chef, Inc., 486 U.S. 399 (1988) (state-law claims are preempted when their resolution requires interpreting a CBA)
- Allis-Chalmers Corp. v. Lueck, 471 U.S. 202 (1985) (state tort claims preempted when inextricably intertwined with CBA interpretation)
- Lightning v. Roadway Express, Inc., 60 F.3d 1551 (11th Cir. 1995) (analyzing when tort claims require referring to CBA terms)
- Sams v. United Food & Commercial Workers Union, AFL/CIO, CLC, 835 F.2d 848 (11th Cir. 1988) (removal and preemption under § 301 justify denial of remand)