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Caterpillar, Inc. v. Williams, 482 U.S. 386 (1987)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Caterpillar, Inc. v. Williams, 482 U.S. 386 (1987)
Caterpillar, Inc. v. Williams No. 86-526 Argued April 21, 1987 Decided June 9, 1987 482 U.S. 386
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR
THE NINTH CIRCUIT
Syllabus
Caterpillar Tractor Co. (Caterpillar) hired respondents to work at its San Leandro, California, facility in positions covered by its collective bargaining agreement with a union. Respondents eventually assumed management and other positions outside the bargaining unit, and allegedly were repeatedly assured by Caterpillar that, if the San Leandro facility ever closed, Caterpillar would employ them at other facilities. Subsequently, they were downgraded to unionized positions, but allegedly assured that the downgrades were temporary. However, Caterpillar later notified them that its San Leandro plant would close and that they would be laid off. Respondents then filed this action, based solely on state law, in a California state court, alleging that Caterpillar thereby breached their individual employment contracts. Caterpillar removed the action to Federal District Court, arguing that removal was proper because any individual employment contracts made with respondents were, as a matter of federal substantive labor law, merged into and superseded by the collective bargaining agreement. Respondents denied that they alleged any federal claim, and sought remand of the action to the state court. The Federal District Court held that removal was proper, and dismissed the case when respondents refused to amend the complaint to attempt to state a claim under § 301 of the Labor Management Relations Act, 1947, which confers federal jurisdiction as to suits for violations of collective bargaining agreements. The Court of Appeals reversed, holding that the case was improperly removed.
Held: Respondents’ state law complaint for breach of the individual employment contracts is not removable to Federal District Court. Pp. 391-399.
(a) The presence or absence of federal question jurisdiction that will support removal is governed by the "well-pleaded complaint rule," under which federal jurisdiction exists only when a federal question is presented on the face of the properly pleaded complaint. Ordinarily, a case may not be removed on the basis of a federal defense, including the defense of preemption, even if the defense is anticipated in the complaint, and even if both parties concede that the federal defense is the only question truly at issue. However, under the "complete preemption doctrine," which is a corollary to the well-pleaded complaint rule, once an area of state law has been completely preempted, any claim purportedly based on that preempted state law is considered, from its inception, a federal claim, and therefore arises under federal law. Pp. 391-394.
(b) Respondents’ state law contract claims are not "completely preempted" § 301 claims. Section 301 governs claims founded directly on rights created by collective bargaining agreements and claims substantially dependent on analysis of such agreements. However, respondents alleged that Caterpillar breached individual employment contracts with them, and § 301 says nothing about the content or validity of such contracts. Although respondents, as bargaining unit employees at the time of the plant closing, could have brought suit under the collective agreement, they, as masters of the complaint, chose not to do so. Moreover, their complaint is not substantially dependent upon interpretation of the collective bargaining agreement. Pp. 394-395.
(c) J. I. Case Co. v. NLRB, 321 U.S. 332, does not support Caterpillar’s contention that, when respondents returned to the collective bargaining unit, their individual employment contracts were subsumed into, or eliminated by, the collective bargaining agreement so as to be preempted by § 301. That decision does not stand for the general proposition that all individual employment contracts are inevitably superseded by a subsequent collective agreement. The fact that an employer may raise such a question in state court and might ultimately prove that the employee’s claims are preempted does not establish that they are removable. Pp. 395-398.
(d) There is no merit to Caterpillar’s argument that § 301 preempts a state law claim when the employer raises only a defense that requires a court to interpret or apply a collective bargaining agreement, such as Caterpillar’s defense claiming that, in its collective bargaining agreement, its unionized employees waived any preexisting individual employment contract rights. The presence of a federal question, even a § 301 question, in a defensive argument does not overcome the paramount policies embodied in the well-pleaded complaint rule. Pp. 398-399.
786 F.2d 928, affirmed.
BRENNAN, J., delivered the opinion for a unanimous Court.
Contents:
Chicago: U.S. Supreme Court, "Syllabus," Caterpillar, Inc. v. Williams, 482 U.S. 386 (1987) in 482 U.S. 386 482 U.S. 387–482 U.S. 388. Original Sources, accessed November 24, 2024, http://originalsources.com/Document.aspx?DocID=KWYWVL2FPKGTEQY.
MLA: U.S. Supreme Court. "Syllabus." Caterpillar, Inc. v. Williams, 482 U.S. 386 (1987), in 482 U.S. 386, pp. 482 U.S. 387–482 U.S. 388. Original Sources. 24 Nov. 2024. http://originalsources.com/Document.aspx?DocID=KWYWVL2FPKGTEQY.
Harvard: U.S. Supreme Court, 'Syllabus' in Caterpillar, Inc. v. Williams, 482 U.S. 386 (1987). cited in 1987, 482 U.S. 386, pp.482 U.S. 387–482 U.S. 388. Original Sources, retrieved 24 November 2024, from http://originalsources.com/Document.aspx?DocID=KWYWVL2FPKGTEQY.
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