Melendez v. S.F. Baseball Assocs. LLC, No. S245607 (Cal. Apr. 25, 2019)
A year and a half ago, the Court of Appeal held that the wage and hour claims in this case were preempted by the Labor Management Relations Act because, even though the claims arise under state law, they factually depended on aspects of the employment relationship that were defined by a collective bargaining agreement. The Supreme Court now weighs in to reverse.
The Court recognizes that the LMRA can preempt state claw claims that require interpretation of a CBA. But it doesn't necessarily preempt claims that merely reference a CBA. The difference can be fuzzy, but generally asks whether the court is called upon to resolve the meaning of an ambiguous term. Here, the wage-and-hour claims in this case require the court to look to a CBA to determine whether the plaintiffs were temporarily terminated, thus triggering an obligation under the Labor Code to pay them immediately. But the court does not need to engage in any interpretation to get the answer.
Court of Appeal reversed.
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