Background
Daniel Martin appealed a district court order denying his motion to remand a putative state-law assault claim against the International Organization of Masters, Mates & Pilots and Matson Navigation Company to state court. Martin alleged the union conspired with the employer to coerce him to violate his rights to bodily integrity by instituting a vaccination requirement.
The court’s reasoning
The court reviewed the denial of the motion to remand de novo. It applied the complete preemption test, which requires that Congress intended to displace the state-law cause of action and provided a substitute cause of action. The court found that Section nine of the Labor Management Relations Act displaced state-law claims alleging breaches of a union’s representative duties. Congress provided a substitute cause of action for breach of the duty of fair representation under federal law. Martin’s claim that the union coerced him to accept unwanted medical treatment by threatening his livelihood was a claim regarding the union’s representational functions, which is governed by federal law.
What it means going forward
Workers alleging that a union breached its duty of fair representation through coercive conduct must bring their claims in federal court under federal labor law, rather than pursuing state-law tort claims in state court.