Hawaiian Airlines, Inc. v. Norris, 512 U.S. 246, 15 (1994)

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260

HAWAIIAN AIRLINES, INC. v. NORRIS

Opinion of the Court

D

The pre-emption standard that emerges from the line of cases leading to Buell—that a state-law cause of action is not pre-empted by the RLA if it involves rights and obligations that exist independent of the CBA—is virtually identical to the pre-emption standard the Court employs in cases involving § 301 of the LMRA, 29 U. S. C. § 185.7 In Allis-Chalmers Corp. v. Lueck, 471 U. S. 202 (1985), the Court applied § 301 pre-emption to a state-law claim for bad-faith handling of a worker's compensation claim because the duties the employer owed the employee, including the duty of good faith, were rooted firmly in the CBA. Its pre-emption finding was based on the fact that "the right asserted not only derives from the contract, but is defined by the contractual obligation of good faith, [so that] any attempt to assess liability here inevitably will involve contract interpretation." Id., at 218.

It cautioned, however, that other state-law rights, those that existed independent of the contract, would not be similarly pre-empted:

"Of course, not every dispute concerning employment, or tangentially involving a provision of a collective-bargaining agreement, is pre-empted by § 301 or other provisions of the federal labor law. . . . Nor is there any suggestion that Congress, in adopting § 301, wished to give the substantive provisions of private agreements the force of federal law, ousting any inconsistent state regulation. . . . Clearly, § 301 does not grant the parties to a collective-bargaining agreement the ability to contract for what is illegal under state law. In extending the pre-emptive effect of § 301 beyond suits for breach

7 Section 301(a) provides federal-court jurisdiction over controversies involving CBA's and "authorizes federal courts to fashion a body of federal law for the enforcement of these collective bargaining agreements." Textile Workers v. Lincoln Mills of Ala., 353 U. S. 448, 451 (1957).

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