Trial court properly concluded section 301 of LMRA preempts Employees’ claims for liquidated damages and attorney fees under Indiana Wage Payment Statute

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UNPUBLISHED
Rubertha Johnson and 317 other former employees of Guide Corporation (collectively, the “Employees”) appeal the trial court’s grant of Guide’s motion for summary judgment and denial of their motion for summary judgment. On appeal, the Employees raise four issues, one of which we find dispositive and restate as whether the trial court properly concluded the Labor Management Relations Act (the “LMRA”) preempted the Employees’ claims for liquidated damages and attorney fees under the Indiana Wage Payment Statute.
Conclusion (slip op. at 14):  The trial court properly concluded that section 301 of the LMRA preempts the Employees’ claims for liquidated damages and attorney fees under the Indiana Wage Payment Statute. Accordingly, we affirm and remand for further proceedings consistent with this opinion. On remand, the trial court should determine whether the CBA’s grievance and arbitration procedures apply to the Employees’ claims pursuant to federal labor law and, if so, whether the Employees failed to exhaust those procedural remedies.  Affirmed and remanded.


Key Analysis
(slip op. at 5, 8, 13):  Section 301 of the LRMA has complete preemptive force, which means that it will displace entirely any state cause of action for violation of contracts between an employer and a labor organization . . . preemption also applies where the state law claim, though not alleging violation of a collective bargaining agreement, nevertheless requires interpretation of one . . . section 301 preemption still applies if the claims are substantially dependent on analysis of the CBA . . . We conclude the Employees’ claims are substantially dependent on analysis of the CBA.

About Bose McKinney & Evans LLP

Bose McKinney & Evans LLP is a business law firm, headquartered in Indianapolis, Indiana, serving both publicly held and privately held businesses, governmental entities and high-growth industries. Our clients include Fortune 100 companies, international manufacturers, national and regional financial institutions, agribusinesses, sports teams, university-incubated start-ups, media, utilities, cities and schools, to name a few. We strive to build strong relationships with our clients as key business advisors, to exceed expectations in the quality of our work, to be knowledgeable about our clients’ businesses and sectors, to be responsive to service needs and to continually seek to improve the delivery of client services. Our ultimate focus is on our clients.
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