Henry Searcy, Jr., a prospective NFL player agent, sought certification from the National Football League Players Association (NFLPA) but was denied after failing a written exam twice. After an internal arbitration upheld the NFLPA's decision, Searcy sued the NFLPA, its Executive Director, and Prometric LLC, the company that administered the exam. Searcy alleged breach of contract, negligence, and other state law claims, arguing the NFLPA changed exam scoring without following its own regulations. The District Court initially dismissed the claims against the NFLPA Defendants for failure to state a claim under Rule 12(b)(6), implicitly assuming it had subject matter jurisdiction. On a prior appeal, the D.C. Circuit clarified that the District Court lacked diversity jurisdiction and instructed it to reconsider whether Section 301 of the Labor Management Relations Act provided federal question jurisdiction through complete preemption. The District Court subsequently concluded that Section 301 did apply and dismissed the claims on the merits. Searcy appealed again, challenging the existence of federal jurisdiction.
The D.C. Circuit reviewed the District Court's finding of subject matter jurisdiction de novo. The court explained that complete preemption is a rare doctrine that converts a state law claim into a federal one, allowing federal courts to exercise jurisdiction. While Section 301 of the LMRA is one of the few statutes that provides for complete preemption, it only applies when state law claims are 'substantially dependent upon analysis of the terms of an agreement made between the parties in a labor contract.' The court found that Searcy's claims challenged the NFLPA's administration of its Agent Regulations, not the terms of the NFL-NFLPA Collective Bargaining Agreement (CBA). Although the Agent Regulations are related to the CBA, they are a separate agreement between the NFLPA and prospective agents, not a labor contract between an employer and a labor organization. Because the resolution of Searcy's claims did not require interpreting the CBA, the claims were not inextricably intertwined with it. Consequently, Section 301 did not completely preempt the state law claims, and the District Court lacked federal question jurisdiction. The court also rejected the NFLPA's argument that Section 9(a) of the National Labor Relations Act provided a basis for jurisdiction, noting that Section 9(a) does not support complete preemption. Finally, the court held that the District Court lacked supplemental jurisdiction over Searcy's Federal Arbitration Act claim because there were no other claims over which the court had subject matter jurisdiction.
The case is remanded to the District Court with instructions to dismiss Searcy's claims against the NFLPA Defendants for lack of subject matter jurisdiction under Rule 12(b)(1). This decision clarifies that the Agent Regulations are not a labor contract covered by Section 301 of the LMRA, limiting the scope of federal jurisdiction in disputes between agents and the NFLPA. It also confirms that the Federal Arbitration Act does not independently create subject matter jurisdiction, requiring an independent basis like diversity or federal question jurisdiction to proceed.
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